[Gnso-epdp-team] [EXTERNAL] NCSG Feedback on EPDP Phase 2/Batch 2 Legal Questions for Bird & Bird

Mark Svancarek (CELA) marksv at microsoft.com
Tue Jan 21 19:16:27 UTC 2020

Hi, I also apologize for sending this in after the deadline.  I didn't see any need to change any of the existing proposes questions.

My concern is not about the questions already being readied for submission.  Rather, I am concerned that we aren't asking about the implications and limits of semi-automated processing of disclosure requests.

By "semi-automated processing", I mean processing which is mostly automated but which contains triggers which pass requests off to a human.  Examples might be "your credentials are valid but I have never received a request from you", "the nature or volume of requests has suddenly changed", the data subject is a child", or "your credentials indicate that you are LEA from a jurisdiction of concern".

All of the models we have discussed can support semi-automated request processing.  
-   In the centralized model, the automation could happen at the central authorizer.  
-   In the hybrid model, each CP could utilize automated processing within their own systems. 
-   And we've had further suggestions for additional hybridization in the recent calls, where CPs pool resources to share an authorizer, or where a central authorizer automates a portion of the requests and hands off some subset of them back to the CP for processing.

-----Original Message-----
From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> On Behalf Of Amr Elsadr
Sent: Monday, January 20, 2020 1:55 AM
To: Mark Svancarek via Gnso-epdp-team <gnso-epdp-team at icann.org>
Subject: [EXTERNAL] [Gnso-epdp-team] NCSG Feedback on EPDP Phase 2/Batch 2 Legal Questions for Bird & Bird


Apologies for not sending these in before the deadline, but attached is the NCSG Team feedback on the Batch 2 legal questions proposed by the Legal Committee to be sent to Bird & Bird.



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