[Gnso-epdp-team] For your review - proposal for an SSAD Hybrid able to evolve to a Centralized and Automated Model + agenda for Thursday's meeting

Mueller, Milton L milton at gatech.edu
Wed Jan 22 22:41:07 UTC 2020

I think this Hybrid proposal is one of those attempts to find a middle ground when you discover that the “middle” is a chasm with no floor.

Just some brief comments about the obvious things as NCSG is preparing comments.

I was opposed in principle to the idea of a standing committee that can redefine policy without a PDP. It struck me as a bad idea. This would become over time a shadow committee that would make policy in a small closed group with no checks and balances.

But when I saw the proposed composition of the standing committee my opposition hardened into pure rage. That composition is not only unacceptable to NCSG, but constitutes what can only be interpreted as a calculated insult to the interests of data subjects, registrants and privacy advocates.

You propose to give two dedicated seats to BC and IPC, which on this issue represent exactly the same constituencies and interests. You add another dedicated seat for SSAC, which also has an interest in disclosure, and is not a GNSO SG. You give multiple seats to CPH. So in effect, EVERY Stakeholder Group in the GNSO except ONE has multiple seats on this standing committee. How does one justify that? What kind of thinking about this problem would come up with that? Janis? Marika? Barry? Can you tell me? I will be very interested in listening to the rationale.

Further, as Volker has noted, the idea of splitting a seat between two completely different units with no common procedures (ALAC and NCSG) is simply impractical.  Additionally, since this idea of a standing committee has no basis in prior discussions, I think we can eliminate it from consideration quite quickly tomorrow.

Dr. Milton L Mueller
Georgia Institute of Technology
School of Public Policy
[IGP_logo_gold block]

From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> On Behalf Of Volker Greimann
Sent: Wednesday, January 22, 2020 4:47 AM
To: gnso-epdp-team at icann.org
Subject: Re: [Gnso-epdp-team] For your review - proposal for an SSAD Hybrid able to evolve to a Centralized and Automated Model + agenda for Thursday's meeting

Hello Marika,

thank you for the new proposal. I note that there is a new proposal included, which is the recommendation of the formation of a steering committee. Where did this come from? If it rises to the level of a proposed recommendation in the draft, it should have originated from the community and seen some consensus amongst our groups, but I recall no such discussion.

I appreciate the apparent desire for something other than a full-fledged PDP to make modifications as time goes by and we learn more about the SSAD and its potential flaws, but I have my doubts that the community has sufficient resources in all groups to staff such a body (It sounds a bit like being condemned to "EPDP for life").

The proposed make-up also seems unbalanced as the 4 CPH members could be outvoted by the 5 non-contracted members, and At-Large and NCSG share one seat (I have my doubts that this could lead to anything but a stalemate for that seat). As a majority is sufficient to send any proposal to the GNSO council (even though it requires a supermajority), this could be problematic.

With regard to Rec 15: Logging, I porpose to clarify that logging should not extend to any personal data disclosed through the system as part of any disclosure decision as that would open up another can of privacy worms.

Rec: 14: I Don't think the "must" in the first paragraph had consensus, or am I mistaken. "should" and "may" are fine, especially since it may not be known whether automation is legally permissible in any specific case unless it leaves the realm of automation and enters the realm of someone looking at the request and making the relevant determination. I am all for automating that which can be automated but ultimately that must be determined by the disclosing parties.

Rec 12: Suggestion: Could we add something to the effect that requestors must/should state in their request for how long they will / expect to retain the data? Also, requestors must always state in their request that in case they intend to share the data with third parties, who those third parties are and what their purposes are.



Am 21.01.2020 um 15:43 schrieb Marika Konings:
Dear EPDP Team,

Please find below the proposed agenda for the next EPDP Team meeting which is scheduled for Thursday 23 January at 14.00 UTC.

Also, you will find attached the proposal for an SSAD Hybrid able to evolve to a Centralized and Automated Model. Please consider this proposal with your respective group and come prepared to Thursday’s meeting to share your groups feedback – this will be crucial to prepare for a productive F2F meeting.  Do note that updates to the preliminary recommendations in the proposal only relate to changes that would bring the preliminary recommendations in line with the proposal described in the document – other comments and/or highlights have been removed for ease of reading and will be considered after the group’s review of the proposal.

Best regards,

Caitlin, Berry and Marika

EPDP Phase 2 - Meeting #41
Proposed Agenda
Thursday, 23 January 2020 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)                     Update from the legal committee
b)                     ICANN follow up on Belgian DPA response to Strawberry letter – see questions suggested by Marc Anderson:
·    Is ICANN expecting an additional communication on the Strawberry letter?
·    Would ICANN org like feedback from the EPDP Team before it meets with the Belgian DPA?

4.       Introduction of Proposal for an SSAD Hybrid able to evolve to a Centralized and Automated Model (“The Chameleon”)
a)                     Staff overview
b)                     EPDP Team reactions
c)                     Confirm next steps

5.                            Plans for F2F meeting in Los Angeles
a)                     Leadership Priorities
b)                    EPDP Team input
c)                     Confirmation of expected homework / preparations by EPDP Team for the LA F2F meeting
d)                    Confirm next steps

6.                            Continue review of issues list (those items not dependent on item #4), if time allows
a)                     See highlighted items on the issue list (to be circulated)
b)                    EPDP Team input
c)                     Confirm next steps

7.                            Wrap and confirm next EPDP Team meeting (5 minutes):
a)                     Monday 27 January 2020 at 9.00 local time at the ICANN office
b)                     Confirm action items
c)                     Confirm questions for ICANN Org, if any


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