[Gnso-epdp-team] Notes and action items - EPDP Meeting #25 - 17 Oct 2019
Volker Greimann
vgreimann at key-systems.net
Mon Oct 21 14:30:28 UTC 2019
Hi Hadia,
the problem with automatic disclosure is that even if it were legally
possible in certain circumstances, it carries with it a certain
liability risk. Naturally therefore, it should be the decision of the
party (-ies) carrying this liability whether they accept this liability
risk or not. From everything Göran has told us, ICANn will not be the
party accepting this liability, so that leaves the contracted parties.
I for one would be open to granting some form of automated access to
certified law enforcement agencies of my own jurisdiction (and others
that may be legally applicable) for example as they have the power to
legally compel me to provide that data, but others may not accept that
liability of short-cutting due process.
6(1)a - is a tricky number, since it also (amongst other requirements)
requires us to provide evidence of that consent, and everytime we act
through third parties, we cannot be sure that the consent we gathered is
actually that of the data subject.
As far as processing for fraud protection, IT security, etc go under the
GDPR, I would advise revisiting this section as you may be surprised as
to whose protection and security this is intended for (that of the
processor and controller, but not that of unrelated third parties). It
is a legitimate purpose for internal processing by the processor but not
for disclosure by a third party who wants to use it for that purpose. So
again, it is not as easy as you think it is.
You are correct that for the balancing test you need to prove that the
interests of the data subject does not override the interests of the
requestor, but for that, you need to look at the specific circumstances.
I think it would be very difficult to automate such a review to find out
the interests of the data subject, let alone figuring out whether they
do not outweigh the interests of the requestor. Maybe Google and
Facebook have that kind of AI tech, but we don't. Again, certain types
of LEA requests may be on a different scale that make this easier.
I have been a big fan of doing the LEA part first and then looking at
what parts of that would be adaptable to other requestors from the
start. With that, we would likely already have another part that would
be ready for development now.
Best,
Volker
Am 21.10.2019 um 15:35 schrieb Hadia Abdelsalam Mokhtar EL miniawi:
>
> Hi ,
>
> At least we can agree that using the accreditation system only for
> identification is a waste of money, resources and defies any kind of
> logical thinking. Also Amr, I don't know why you see automatic
> disclosure as impossible (provided of course that it abides by the
> law) Whether automatic disclosure will be possible or not will depend
> on the lawful basis used for disclosure and on the specific context
> and circumstances (under some lawful basis and not all). So for
> example if you are disclosing data under 6(1)(a) -consent for specific
> purposes- I would argue that automating this is both desirable and
> possible. But also if we look at the disclosure of the data under
> 6(1)(f) (legitimate interest) In order to decide whether to disclose
> the data or not you will need to perform a legitimate interest
> assessment which would consist of three parts
>
> Purpose test
>
> Necessity test
>
> Balancing test
>
> For the purpose test, legitimate interest may include a wide range of
> purposes, however GDPR specifically mentions fraud prevention, IT
> security and criminal acts as legitimate interests so if you have
> parties accredited for specific purposes they can automatically pass
> this test.
>
> For the necessity test you need to prove that there is no other
> logical, less intrusive way to achieve your purpose, again if you have
> parties accredited for specific purposes this test can also be automated.
>
> For the balancing test you need to prove that the interests of the
> data subject does not override the interests of the requestor and
> again under similar contexts and circumstances maybe this could be
> possible.
>
> I am not trying now to decide what can or cannot be automated as this
> will need thorough studying, but what I am trying to say that it is
> not useful to anyone to just decide that automatic disclosure would be
> impossible. We might be wasting good implementation solutions and
> practices if we come up with a policy that states so.
>
> Best
>
> Hadia
>
> *From:*Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] *On
> Behalf Of *Amr Elsadr
> *Sent:* Monday, October 21, 2019 1:43 PM
> *To:* Volker Greimann
> *Cc:* gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] Notes and action items - EPDP Meeting
> #25 - 17 Oct 2019
>
> Hi,
>
> I think we need to be very clear on what we’re discussing, and what
> different groups might be seeking or agreeing to. Alex pointed out a
> number of areas where automation may be helpful in processing
> disclosure requests, which we should take in to consideration.
>
> However, the notion of */“automatic disclosure”/* (which to me,
> includes the decision and actual action/performance of disclosure) is
> not one that I imagine could be worked out, without infringing on the
> rights of registrants. I’m open to listening to why some might find
> that to be incorrect or not a sufficient deterrent, but right now, my
> view is likely the opposite of the IPC’s. I don’t believe we should be
> recommending a policy that allows for automatic disclosure under any
> circumstance.
>
> So regarding action item 1, this part of the discussion should not
> result in any update to the Accreditation Building Block. Like Volker
> said, there is no agreement on this specific point.
>
> Thanks.
>
> Amr
>
>
>
> On Oct 21, 2019, at 1:25 PM, Volker Greimann
> <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>> wrote:
>
> 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
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> 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
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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.
>
--
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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