[Gnso-epdp-team] Proposed agenda - EPDP Team meeting #20 on Tuesday 24 September at 14.00 UTC

Mon Sep 23 21:06:51 UTC 2019

I think there has been a misunderstanding as to what I have proposed.

The intent here is not to overengineer anything, but to borrow from existing practices in other areas/fields. Anyone who has submitted a Freedom of Information (FOI) request before to the US government or to a European institution will have received a Receipt Acknowledgement Letter.

If you have not seen one before, I have attached one that I found at random just now - it is from the first page of a Google search, so there is no special significance to it.

As you can see, it acknowledges that the request has been received, includes a unique reference number for the request, lays out the processor's timeline for handling these requests, and provides a point of contact for questions. In an SSAD context, I fully envision this being an email and not distributed via the postal service.

There should not be a need for any request to be examined twice by a contracted party, nor should the issuance of such a document prevent you from immediately examining the request. Only certain, basic types of corrections would be permissible following the submission of a request -- change a typo in an email address for instance. Much like an FOI request, you could not alter anything that materially changed it.

Ayden

‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
On Monday, 23 September 2019 10:42, Volker Greimann <vgreimann at key-systems.net> wrote:

> Wjhile I appreciate the intent of this, this seems to be very difficult to operationalize. Ideally, we would look at any one request once, maybe twice if it is deficient in some way. Adding in all this overhead seems to be a recipe for decreasing response times and increasing the time a request spends in the queue.
>
> Volker
>
> Am 21.09.2019 um 20:41 schrieb Ayden Férdeline:
>
>> Hi,
>>
>> Regarding building block k, I have alternate language that I would like to table for consideration please.
>>
>> The language circulated in the below email is:
>>
>> Building Block k) (Receipt of acknowledgement)
>>
>> The EPDP Team recommends that, consistent with the EPDP Phase 1 recommendations, the response time for acknowledging receipt of a SSAD request should be without undue delay, but not more than two (2) business days from receipt, unless shown circumstances does not make this possible.
>>
>> The response should also include information about the subsequent steps as well as the timeline consistent with the recommendations outlined below.
>>
>> Proposed new language (changes in red):
>>
>> Building Block k) (Acknowledgement of request)
>>
>> The EPDP Team recommends that upon receipt of an SSAD request, the receiving entity shall issue a Receipt Acknowledgement Letter which summarizes the applicant’s requests. This should happen without undue delay and, ideally, within two business days of the request being received by the receiving entity. This response shall include information about the subsequent steps to be taken as well as a timeline for its processing. Following the issuance of the Receipt Acknowledgement Letter, the applicant shall have a fourteen-calendar-day period within which it may make certain types of corrections to its request. This is to permit the applicant to correct data entry errors, change contact information, and to withdraw the request if it is no longer required. Similarly, the receiving entity of the request shall inform the data subject(s) whose personal information is sought, unless prohibited to make such a disclosure by law, and provide the data subject with a reasonable window of time and the opportunity within which they may object to their data being processed.
>>
>> Kind regards,
>>
>> Ayden Férdeline
>>
>> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
>> On Saturday, 21 September 2019 02:19, Marika Konings [<marika.konings at icann.org>](mailto:marika.konings at icann.org) wrote:
>>
>>> Dear EPDP Team,
>>>
>>> Please find attached the proposed agenda for the next EPDP Team meeting which is scheduled for Tuesday 24 September at 14.00 UTC. To facilitate your preparation, please review the attached documents which include in addition to the relevant section from the zero draft, the relevant section from the SSAD worksheet that contains information in relation to the objective of addressing the topic as well as materials to review.
>>>
>>> Best regards,
>>>
>>> Caitlin, Berry and Marika
>>>
>>> ===========
>>>
>>> EPDP Phase 2 - Meeting #20
>>>
>>> Proposed Agenda
>>>
>>> Tuesday, 24 September 2019 at 14.00 UTC
>>>
>>> 1.                            Roll Call & SOI Updates (5 minutes)
>>>
>>> 2.                            Confirmation of agenda (Chair)
>>>
>>> 3.                            Welcome and housekeeping issues (Chair) (5 minutes)
>>>
>>> a)                     Reminder - the EPDP Team members to populate the contents of the lawful basis table by Wednesday 25 September (see [https://docs.google.com/document/d/1U9jt9nOHs9QMjWTDl7UPaT--                9aD2lHZI/edit](https://docs.google.com/document/d/1U9jt9nOHs9QMjWTDl7UPaT--%099aD2lHZI/edit))
>>>
>>> b)                     Reminder - submit alternate form if members are not attending the Jan 2020 F2F meeting
>>>
>>> 4.                            Acceptable Use Policy (Building block d & h) – first reading (30 minutes).
>>>
>>> a)                      Initial discussion
>>>
>>> b)                     Feedback from EPDP Team
>>>
>>> c)                      Confirm next steps
>>>
>>> 5.                            Receipt of acknowledgement (building block k) – first reading (30 minutes)
>>>
>>> a)                      Initial discussion
>>>
>>> b)                     Feedback from EPDP Team
>>>
>>> c)                      Confirm next steps
>>>
>>> 6.                            Who should be responsible for disclosure decision (15 minutes)
>>>
>>> a)                      Review additional team input provided (see https://docs.google.com/document/d/10VRZRziGDXvckC_y3ob_SGB-1NN9WrL6Y6A3XQuniv8/edit)
>>>
>>> b)                     Consider team input and approach forward
>>>
>>> c)                      Confirm next steps
>>>
>>> 7.                            Wrap and confirm next EPDP Team meeting (5 minutes):
>>>
>>> a)                      Thursday 26 September 2019 at 14.00 UTC
>>>
>>> b)                     Confirm action items
>>>
>>> c)                      Confirm questions for ICANN Org, if any
>>>
>>> Marika Konings
>>>
>>> Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN)
>>>
>>> Email: marika.konings at icann.org
>>>
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>>>
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>>
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>
> --
> Volker A. Greimann
> General Counsel and Policy Manager
> KEY-SYSTEMS GMBH
>
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