[Gnso-epdp-team] Notes and action items - EPDP Meeting #25 - 17 Oct 2019

Volker Greimann vgreimann at key-systems.net
Mon Oct 21 11:25:08 UTC 2019


Hi JK,

we are not disagreeing here, I think, just trying to clarify our 
understanding. I also agree to that principle.

Best,

Volker

Am 21.10.2019 um 12:48 schrieb Janis Karklins:
> Volker,
>
> I had impression that the principle that "SSAD should be as much 
> automated as possible and standardized for the rest" was agreed by all 
> groups in the Team already a while ago.
>
> When we are thinking about implementability and scaleability of the 
> system, ambiguities in formulations may not be helpful. I understand 
> that on some issues groups may have divergent or even opposing 
> opinions. We should be as flexible as possible and as precise as 
> possible and look at the SSAD as a package of different compromises by 
> all groups.
>
> JK
>
> On Mon, Oct 21, 2019 at 2:45 AM Volker Greimann 
> <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>> wrote:
>
>     Hi Alex,
>
>     thank you for your response. I don't think that anyone opposes the
>     idea that certain aspects of the system can and should be
>     automated, however that is not the general usage of the term in
>     this group so far. "To automate" was always discussed in the
>     context of automating the disclosure decision, and in that
>     context, we cannot support this language.
>
>     I think it would be helpful if we were all more clear in what we
>     mean when we use certain words.
>
>     Automating completeness, error checking and notices of receipt
>     makes sense and it would be very much appreciated if the system
>     takes care of that for us, but that is not what we mean by
>     "automation".
>
>     To your last points, I think we have established that all requests
>     will likely be those of the 6.1.f. variety, and those all include
>     that notorious balancing test which needs to take into
>     consideration facts that are not part of the request and in my
>     view cannot be automated.
>
>     My personal position on this is that this point can be left open:
>
>     If a disclosing CP feels that they can automate that part as well,
>     they should be able to do so, but we should not mandate it. So by
>     striking the reference at this point, we do not prohibit such
>     automation, but we also do not mandate it. That strikes me as a
>     workable compromise between our positions, won't you agree?
>
>     Best,
>
>     Volker
>
>     Am 20.10.2019 um 19:02 schrieb Alex Deacon:
>>     Volker and all,
>>
>>     Our thoughts on the topic of automation.
>>
>>     The IPC objects to any policy that does not allow for the
>>     automation of request/response processing.    Once again I remind
>>     everyone we are defining policy for a *system* that will be RDAP
>>     based - not a process that is based on "old fashioned" technology
>>     like smoke signals, wax sealed correspondence written by quill
>>     and ink, telex messages, faxes or email.   (We already did this
>>     in Phase 1 Rec 18)
>>
>>     Clearly we want a policy that allows for the automation of syntax
>>     checking of incoming requests, resulting in an automatic response
>>     that indicates the errors to the requestor.   This automation
>>     addresses the risk of filling up the request queues of the
>>     discloser with malformed requests.
>>
>>     Clearly we want a policy that allows for the automation of
>>     checking that the contents of a request is complete, based on
>>     policy we are setting in another building block, resulting in an
>>     automatic response that details what is be missing (per policy).
>>        This automation allows for the discloser to indicate - without
>>     human intervention - what additional information is required per
>>     policy and enables the requestor to address the error.
>>
>>     Clearly we want a policy that allows for the automation of an
>>     immediate and synchronous response that indicates the receipt of
>>     a valid request and some indication that it will be processed.  
>>     Typically such responses include a "ticket number" or some kind
>>     of uniqueID to allow for future queries (status, updates,
>>     deletion, etc.).   This automation allows for efficient queue
>>     management on the disclosers side and assists in ensuring our
>>     principal of "predictability" is met for the requestor.
>>
>>     It is important to note that in none of the three points above do
>>     I state or even suggest that automation will or can result in the
>>     automatic response of non-public data.
>>
>>     However having said that - there is no doubt in my mind that
>>     there will exist some subset of well formed, valid, complete,
>>     properly identified and accredited requests for some subset of
>>     legal basis and some subset of purposes that indeed can be
>>     automatically processed and result in the disclosure of
>>     non-public RDS data without human intervention.    The IPC would
>>     object to any policy language that would explicitly forbid this
>>     from ever happening.
>>
>>     Thanks.
>>     Alex
>>     ___________
>>     *Alex Deacon*
>>     Cole Valley Consulting
>>     alex at colevalleyconsulting.com <mailto:alex at colevalleyconsulting.com>
>>     +1.415.488.6009
>>
>>
>>
>>     On Fri, Oct 18, 2019 at 1:01 PM Volker Greimann
>>     <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>> wrote:
>>
>>         Hi Caitlin,
>>
>>         I don't think 4.B) Principle B:
>>
>>           * What does accreditation mean? The group discussed the
>>             potential for allowing for the automatic disclosure where
>>             allowed under the law suggest “and automation of
>>             responses where possible under applicable law”
>>
>>         truly captures the content of our disscussion. The draft
>>         should only contain agreed language and the inclusion of "and
>>         automation of" was very much not agreed. In fact this
>>         language was opposed by a large group and therefore should be
>>         removed unless approved.
>>
>>         -- 
>>         Volker A. Greimann
>>         General Counsel and Policy Manager
>>         *KEY-SYSTEMS GMBH*
>>
>>         T: +49 6894 9396901
>>         M: +49 6894 9396851
>>         F: +49 6894 9396851
>>         W: www.key-systems.net <http://www.key-systems.net/>
>>
>>         Key-Systems GmbH is a company registered at the local court
>>         of Saarbruecken, Germany with the registration no. HR B 18835
>>         CEO: Alexander Siffrin
>>
>>         Part of the CentralNic Group PLC (LON: CNIC) a company
>>         registered in England and Wales with company number 8576358.
>>
>>
>>         On Fri, Oct 18, 2019 at 1:17 AM Caitlin Tubergen
>>         <caitlin.tubergen at icann.org
>>         <mailto:caitlin.tubergen at icann.org>> wrote:
>>
>>             Dear EPPD Team:
>>
>>             Please find below the notes and action items from today’s
>>             EPDP Team meeting.
>>
>>             The next EPDP Team meeting will be *Tuesday, 22 October*
>>             at 14:00 UTC.
>>
>>             Best regards,
>>
>>             Marika, Berry, and Caitlin
>>
>>             *EPDP Phase 2 - Meeting #25*
>>
>>             *Proposed Agenda*
>>
>>             Thursday, 17 October 2019 at 14.00 UTC
>>
>>             _Action Items_
>>
>>              1. Support Staff to update the text of the Accreditation
>>                 Building Block
>>                 <https://docs.google.com/document/d/1zAEBygpoddKOJOfb1whMtaQHcik856aZZc9BoDk392E/edit>
>>                 and Financial Sustainability Block
>>                 <https://docs.google.com/document/d/1Ci-wvA1P9yoKjJ5DPeRbZ5FOHL2D8ExGsN2SV9TPELM/edit>
>>                 based on today’s discussion.
>>              2. EPDP Team to provide additional edits in the
>>                 Accreditation Building Block
>>                 <https://docs.google.com/document/d/1zAEBygpoddKOJOfb1whMtaQHcik856aZZc9BoDk392E/edit>
>>                 re: implementation guidance and definitions by COB
>>                 tomorrow, *Friday, 18 October*.
>>              3. EPDP Team to provide additional edits from today’s
>>                 conversation to the Financial Sustainability Block
>>                 <https://docs.google.com/document/d/1Ci-wvA1P9yoKjJ5DPeRbZ5FOHL2D8ExGsN2SV9TPELM/edit>
>>                 by *Friday, 18 October*.__
>>              4. EPDP Volunteers needed to propose initial text for
>>                 Building Block M – Terms of Use/Disclosure
>>                 Agreements/Privacy Policies
>>                 <https://docs.google.com/document/d/1eZBzRclRtEXPp1EScDfftnfnv9tneD7ovxmGe84BQz4/edit>
>>                 by *Monday, 21 October*.__
>>
>>             1.Roll Call & SOI Updates (5 minutes)
>>
>>             2.Confirmation of agenda (Chair)
>>
>>             3.Welcome and housekeeping issues (Chair) (5 minutes)
>>
>>             a)Update from legal committee
>>
>>             b)Status of building blocks
>>             <https://community.icann.org/x/k5ICBw>
>>
>>             4.Accreditation
>>             <https://docs.google.com/document/d/1EOZY0oNiBrtAOZeka3LCMwyMiaGjSJLVDTcyVl4YnHY/edit>(building
>>             block f and j) – second reading continued (30 minutes)
>>
>>             a)Overview of implementation guidance section
>>
>>             b)Feedback from EPDP Team
>>
>>             Principle b
>>
>>               * Requirements should be spelled out as part of the
>>                 policy discussion
>>               * There will be different types of entities and may
>>                 have different documentation to provide
>>               * These requirements should be as uniform as possible
>>               * C may need to come before B
>>               * There needs to be an underlying baseline of
>>                 requirements that are uniform.
>>               * Accreditation is all about identification; thought
>>                 the group agreed that accreditation is at a minimum
>>                 about identity, but it could also establish other
>>                 things as well – such as law enforcement, cyber
>>                 security, etc.
>>               * It would be helpful to draw a line b/w the
>>                 accreditation process and what needs to be included
>>                 in the disclosure request – parties seeking
>>                 accreditation should probably not have to include
>>                 every scenario where a law enforcement would have to
>>                 interface with the SSAD – hoping the Team can be more
>>                 specific with baseline requirements for accreditation
>>               * Law enforcement will likely have a different
>>                 accreditation system than other entities, so that
>>                 conversation should be separate
>>               * What does accreditation mean? The group discussed the
>>                 potential for allowing for the automatic disclosure
>>                 where allowed under the law suggest “and automation
>>                 of responses where possible under applicable law”
>>               * Accreditation does not equate to automated response
>>                 by default – each query will be decided upon on its
>>                 own merits
>>               * Certain types of people (user groups) may allow for
>>                 streamlining – some categories may involve more
>>                 scrutiny – to that extent, accreditation is more than
>>                 authentication of identity
>>               * By adding too much into one subject, the discussion
>>                 is encumbered. The discussion of accreditation and
>>                 authentication should be decoupled.
>>               * The small team for accreditation agreed that
>>                 accreditation is not authorization. It might be
>>                 desirable and helpful to have attributes associated
>>                 with accreditation. The only attribute that will
>>                 consistently make a difference is whether it is law
>>                 enforcement or not. With respect to cyber security
>>                 researchers, any IT person could legitimately claim
>>                 to be doing cyber security research. There shouldn’t
>>                 be entry barriers that say you are or are not cyber
>>                 security researchers.
>>               * The building block includes a list of definitions,
>>                 which the Team has not yet discussed.
>>               * If accreditation only proves identity, the Team is
>>                 limiting what it can discuss with regard to the
>>                 release of data.
>>               * Support Staff to try to analyze what was said during
>>                 the conversation with respect to Subpoint B and
>>                 Subpoint C for online consideration
>>
>>             Principle d
>>
>>               * What is the expectation for what de-accreditation means?
>>               * Accreditation would be that the accreditation is who
>>                 they say they are; as a result, there is access to
>>                 the system without further verification of identity.
>>                 If an entity is de-accredited, it would need to be
>>                 re-accredited.
>>               * This would mean that the authority could revoke
>>                 access to the system, not “de-accredit”.
>>
>>             Principle g
>>
>>               * What is the accreditation policy and requirements –
>>                 where is this?
>>               * The accreditation policy and associated requirements
>>                 have not been drafted/implemented yet
>>
>>             Principle i
>>
>>               * Issue with replaced “must be paid for service” with
>>                 “cost-recovery system” – this could suggest that the
>>                 costs need to be covered by another form. The whole
>>                 system is for the benefit of third-party users who
>>                 would request disclosure of registration data –
>>                 concerned with costs being shifted to registrants
>>               * Two types of costs involved – development and
>>                 deployment of the system and then the cost of
>>                 day-to-day running of the system
>>               * The costs need to be considered in a cost-recovery
>>                 system. The purpose of accreditation is to lower
>>                 these costs. Whatever cost-recovery system takes
>>                 place – these costs need to be recovered from the
>>                 users of the system, not from registrants or
>>                 contracted parties.
>>               * Have issues with the terms “significantly reduce”.
>>                 This is a separate system. The Team really needs to
>>                 consider a cost-benefit analysis of figuring out
>>                 someone’s ID – how much will this actually cost? Is
>>                 it achievable?
>>               * Perhaps the second sentence could be moved to Block N.
>>               * There are two sets of development costs –
>>                 accreditation system and SSAD. This paragraph should
>>                 be limited to the development of the accreditation
>>                 system. Re: development of SSAD – that should be
>>                 moved to Building Block N.
>>               * Agree with moving the second sentence to Building
>>                 Block N. If the benefit exceeds the cost, there needs
>>                 to be an escape valve in the policy. As a policy
>>                 principle, it should be the benefits of the SSAD
>>                 system must outweigh the costs.
>>               * If there are too many requirements, the system will
>>                 be too expensive. Avoid saying the costs outweigh the
>>                 benefits. This language needs more work to make it
>>                 clear what the team is after.
>>               * Maintain first sentence and delete second sentence
>>               * This conversation can be moved to the financial
>>                 building block.
>>               * Registrants do get something from the SSAD – a
>>                 reliable and secure DNS. The SSAD is not a clean
>>                 slate – the current system is the registrars having
>>                 to do the work themselves, and someone is paying for
>>                 this.
>>               * There is a clean and reliable DNS system today – to
>>                 say “cleaner” and “more reliable” would be
>>                 preferable. Costs may be occurring in other areas
>>                 that are offset for a system that doesn’t currently
>>                 exist is problematic and disproportionate.
>>
>>             Principle k
>>
>>               * The use of the word “tagging” is confusing
>>               * Marc to submit proposed updated online
>>               * What is the meaning b/w the first and second sentence?
>>               * The SSAD takes requests from accredited and
>>                 unaccredited users, so unaccredited users will be
>>                 treated a different way. RDAP is a query response
>>                 protocol, where you query the system and get a
>>                 response back. There will now be instances where some
>>                 queries will be responded to right away and others
>>                 will be queued (for balancing tests have to be
>>                 conducted) and the response will be returned later –
>>                 RDAP was not designed to be used in this way.
>>               * The second sentence in k does not make sense.
>>
>>             Implementation Guidance Feedback
>>
>>               * Drafting note c – legitimate and lawful purpose
>>                 described above (stated)
>>               * Some implementation belongs in the policy – a and b
>>                 could be left in implementation guidance. C and D
>>                 could be left in the policy language as opposed to
>>                 implementation guidance.
>>               * De-accreditation – this will depend on what the
>>                 specifics of accreditation are and what it would mean
>>                 for someone to be de-accredited
>>               * At the F2F, the Team talked about de-accreditation
>>                 for the users of the system and the accrediting
>>                 entities. E and G are potentially in conflict with
>>                 each other.
>>               * What does access to the system mean? Even bad actors
>>                 should have access to the public data.
>>               * This hinges on unaccredited users having access to
>>                 the system – is the SSAD being used by everyone, or
>>                 just accredited users?
>>               * Can the Team agree that the SSAD could be used by
>>                 both accredited and non-accredited users? The
>>                 difference is that accredited entities will query the
>>                 system w/o verification of the entity.
>>               * SSAD should be usable by everyone and not exclude anyone
>>               * How one does identity verification is a decision
>>                 ICANN should be making in the public interest.
>>               * Concern that individuals should not be prevented from
>>                 getting access to data they may need to protect their
>>                 domain name
>>
>>             c)Confirm next steps
>>
>>               * Support Staff to update the text of the Accreditation
>>                 Building Block based on today’s discussion. EPDP Team
>>                 to provide additional edits in the Google Doc for
>>                 implementation guidance and definitions by COB
>>                 tomorrow, Friday, 18 October.
>>
>>             5.Financial Sustainability
>>             <https://docs.google.com/document/d/1Ci-wvA1P9yoKjJ5DPeRbZ5FOHL2D8ExGsN2SV9TPELM/edit>(building
>>             block n) – second reading
>>
>>             a)Overview of updates made following first reading
>>
>>             b)Feedback from EPDP Team
>>
>>               * Third paragraph: cost-recovery basis is used in
>>                 multiple places. The Team needs to define this term.
>>                 Cost-recovery is a term of art in accounting, and
>>                 that definition is probably not what the Team meant here.
>>               * Cost recovery may mean different things to different
>>                 people. Also, what does “historic costs” mean in this
>>                 context? The users of the system should be sustaining
>>                 the capability of the system on an ongoing basis.
>>               * Second paragraph – object to contracted parties
>>                 bearing the costs.
>>               * Different parties will bear different costs – this
>>                 language does not explain that division of
>>                 responsibilities. For example, accredited entities
>>                 will bear the costs of getting accredited. The
>>                 parties who are receiving the queries that contracted
>>                 parties would be responsible for setting up their
>>                 systems to receive queries and respond to them.
>>               * Registrants being beneficiaries of the system may be
>>                 a tenuous argument
>>               * Fourth paragraph – in favor or usage-based fees that
>>                 sustain the operation of this system.
>>               * A system cannot be costed out unless we know what the
>>                 system is designed to do.
>>
>>             c)Confirm next steps
>>
>>             6.Terms of use / disclosure agreements / privacy policies
>>             <https://docs.google.com/document/d/1eZBzRclRtEXPp1EScDfftnfnv9tneD7ovxmGe84BQz4/edit>(building
>>             block m) – first reading
>>
>>             a)Review building block
>>
>>             b)Feedback from EPDP Team
>>
>>             c)Confirm next steps
>>
>>             7.Wrap and confirm next EPDP Team meeting (5 minutes):
>>
>>             a)Tuesday 22 October 2019 at 14.00 UTC
>>
>>             b)Confirm action items
>>
>>             c)Confirm questions for ICANN Org, if any
>>
>>             _______________________________________________
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>     -- 
>     Volker A. Greimann
>     General Counsel and Policy Manager
>     *KEY-SYSTEMS GMBH*
>
>     T: +49 6894 9396901
>     M: +49 6894 9396851
>     F: +49 6894 9396851
>     W: www.key-systems.net <http://www.key-systems.net>
>
>     Key-Systems GmbH is a company registered at the local court of
>     Saarbruecken, Germany with the registration no. HR B 18835
>     CEO: Alexander Siffrin
>
>     Part of the CentralNic Group PLC (LON: CNIC) a company registered
>     in England and Wales with company number 8576358.
>     _______________________________________________
>     Gnso-epdp-team mailing list
>     Gnso-epdp-team at icann.org <mailto:Gnso-epdp-team at icann.org>
>     https://mm.icann.org/mailman/listinfo/gnso-epdp-team
>     _______________________________________________
>     By submitting your personal data, you consent to the processing of
>     your personal data for purposes of subscribing to this mailing
>     list accordance with the ICANN Privacy Policy
>     (https://www.icann.org/privacy/policy) and the website Terms of
>     Service (https://www.icann.org/privacy/tos). You can visit the
>     Mailman link above to change your membership status or
>     configuration, including unsubscribing, setting digest-style
>     delivery or disabling delivery altogether (e.g., for a vacation),
>     and so on.
>
-- 
Volker A. Greimann
General Counsel and Policy Manager
*KEY-SYSTEMS GMBH*

T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
W: www.key-systems.net

Key-Systems GmbH is a company registered at the local court of 
Saarbruecken, Germany with the registration no. HR B 18835
CEO: Alexander Siffrin

Part of the CentralNic Group PLC (LON: CNIC) a company registered in 
England and Wales with company number 8576358.
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