[Gnso-epdp-team] Financial sustainability issues of the SSAD

[Janis Karklins]

Goran,

I am writing you in my capacity of the Chair of the EPDP Phase 2 Team to
seek input on financial sustainability issues if the SSAD.

The EPDP Phase 2 Team is considering the financial sustainability of the
System for Standardized Access/Disclosure (SSAD) currently being
deliberated. This will likely involve ICANN managing or operating a
centralized system to facilitate requests for disclosure of non-public gTLD
registration data.

 The Team is contemplating how considerable cost implications would be to
develop, operationalize and run such a System. The EPDP currently considers
principles on which such a system may be based. Work is still in progress,
but the Team is discussing principles such as:

1.            The SSAD should operate on a cost-neutral basis. No party
should operate or seek to operate this service as a for-profit service, as
this would invite abuse and manipulation of the SSAD functions.

2.            Costs to operate the SSAD should be borne by the *direct*
beneficiaries of the service. The costs of SSAD should not be transferred
to Data Subjects (Registrants), either directly via fees from ICANN or
indirectly via fees to Contracted Parties who provide the SSAD with data
and bear the legal risks of disclosures.

In the absence of responses from both the EPDP letter to the Board, and to
the Strawberry Team’s query as presented to the European Data Protection
Board, the EPDP team is not in a position to consider a single model for
the potential SSAD. Accepting that financial sustainability is a vital
consideration for the initial report, and as we have not yet determined the
model for the SSAD, we must therefore present the financial sustainability
of each of the general model types so far postulated:

   - Fully Centralized (e.g. with ICANN at the core)
   - Centralized Accreditation and request portal, distributed
   decision-making, with final response via Centralized portal (e.g. CZDS).
   - Central Gateway, with distributed review and disclosure

The Team understands that a cost analysis is difficult to conduct while the
exact details of the SSAD are still being determined. We hope that looking
at existing systems such as TMCH or CZDS might provide useful baselines and
identify dependent assumptions that impact cost models. CZDS, for example,
is itself a centralized system for access to data (in this case zone file
data), sharing many similarities with the SSAD being contemplated.

Equally, financial sustainability analysis of the UAM could provide same
useful indications for Team’s deliberations.

In order to understand if it is possible for the SSAD to adhere to these
crucial principles, we are requesting ICANN Org’s help in understanding all
the likely costs associated with both the development and the ongoing
operation of the SSAD. Once we understand the anticipated costs, we would
expect to propose a credentialing and transaction fee structure which would
pay for the System and allow us to better understand the cost/benefit
balance of the SSAD as a whole.

Your input on financial sustainability issues will be highly appreciated.

Best regards

JK
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