[Gnso-epdp-team] RrSG initial comment on SSAD Registrant user group

Mon Jun 10 14:10:47 UTC 2019

Yes, data subjects can request their data from a party that holds it; those kinds of GDPR requests are sometimes made through out-of-band methods and don’t require the data subjects to be system users with system accounts. 

The operator must be able to respond to requests from data subjects… but for completeness, it must do so AFAIK ONLY IF the operator holds the data.   Most models discussed so far don’t have the SSAD operator storing all the data – it could merely shuttle data back and forth.  The group will no doubt discuss that design aspect more later. 

All best,

--Greg

From: Alan Woods <alan at donuts.email> 
Sent: Friday, June 7, 2019 11:06 AM
To: Greg Aaron <greg at illumintel.com>
Cc: Sarah Wyld <swyld at tucows.com>; GNSO EPDP <gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] RrSG initial comment on SSAD Registrant user group

Thank you Sarah.

Greg just for completeness, an EU data subject will of course still be entitled to exercise their rights against the 'SSAD' also. If their data is processed within the SSAD then whoever is the guardian of that system, shall have to have 

a) a viable and robust process for dealing with such requests directly themselves (assuming they are a controller), and/or

 b) provide the necessary information and aid to other controllers dealing with such requests in this data processing ecosphere (especially Art 17). 

But I do agree, expecting them to have to be a "subscribed" or "credentialed"  user in order to exercise such rights is a very bad idea. 

Alan

 <http://donuts.domains/> 

Alan Woods

Senior Compliance & Policy Manager, Donuts Inc. 

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On Fri, Jun 7, 2019 at 3:33 PM Greg Aaron <greg at illumintel.com <mailto:greg at illumintel.com> > wrote:

Agree.  Registrants already have the appropriate means to view their own sensitive data fields and update their domain data: the registrar’s system.  And that provides controlled, permissioned access for the registrants to see their data and theirs only.  And registrants will have public access to RDS to see non-sensitive data about their domains.

To offer registrants access to the SSAD System on top of that would be a nightmare from an access management view.  (How would registrants get credentials into a SSAD, and how would that system know what records the registrant is allowed to see?)   SSAD is for third parties who need to access non-public data.

All best,

--Greg

From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org <mailto:gnso-epdp-team-bounces at icann.org> > On Behalf Of Sarah Wyld
Sent: Thursday, June 6, 2019 9:36 AM
To: gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org> 
Subject: [Gnso-epdp-team] RrSG initial comment on SSAD Registrant user group

Hello all,

The RrSG has significant concerns with the inclusion of Registrants as a user group for the System for Standardized Disclosure of non-public gTLD registration data, and strongly recommends that this group be removed from the proposed list of users. We are curious as to the origin of these proposed user groups, and suggest that instead of working through this list we begin by reviewing the purposes for processing data (Recommendation 1) and assessing the potential user group applicable to each purpose. 

Registrants already access their domains via their service provider (registrar or reseller)’s system, as required under the RAA. Having multiple interfaces to access the same information poses a significant risk of inappropriate data exposure; this unnecessary and unbalanced security risk is not compliant with data protection law. It also creates a confusing user experience for the registrant. For example, if a registrant uses the SSAD to review their domain data for the purpose of confirming that it is accurate, they would still need to work with their service provider to confirm that the data held in that system is also up to date.  

The RrSG notes that a system used to access or disclose data is not also a system to modify that data. The EPDP team definitions of access and disclosure do not include any capability to modify the data, so this is a new addition to the requirements not grounded in any previously agreed-upon basis or definition. Modification of domains via the SSAD could easily result in synchronization issues and security risks, where the SSAD holds data that is different from what is in the registrar or reseller’s platform, or an unauthorized party could modify and even hijack a registered domain. This also represents a fundamental shift from the system in place for the past twenty years: EPP is one-directional, with data flowing from the reseller or registrar through to the registry, so any functionality for updating domain data would need to be created and implemented by thousands of service providers worldwide. 

We look forward to discussing this important concern at today’s EPDP team call. Beyond these concerns about the “Registrants” group, we are also uncertain that “end users” is a valid group; this and the other groups should be discussed with the plenary team.  

-- 
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392

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