[Gnso-epdp-team] Purpose 2
Hadia Abdelsalam Mokhtar EL miniawi
Hadia at tra.gov.eg
Thu Mar 5 10:21:41 UTC 2020
We need not forget that data subjects need to know with whom their data might be shared and for what purposes. To this end purpose 2 is important as it establishes one core purpose for processing the data related to ICANN's mission and stated in its bylaws. Also in the EC letter to Joran in May 2019 under purposes of processing and access model, the EC say "For this reason we would recommend revising the formulation of purpose two by excluding the second part of the purpose "through enabling responses to lawful data disclosure requests" and maintaining a broader purpose " Contribute to the maintenance of the security, stability and resiliency of the Domain Name System in accordance with ICANN's mission"
This was the recommendation of the EC to us in May 2019, the question now is why don't we want to follow this recommendation? Maintaining the SSR of the internet is ICANN's core mission and is indeed a purpose for which data might be processed why don't we want to be clear about this.
From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] On Behalf Of Alan Greenberg
Sent: Thursday, March 05, 2020 2:18 AM
To: Margie Milam; brian.kingATmarkmonitor.com; gnso-epdp-team at icann.org
Subject: Re: [Gnso-epdp-team] Purpose 2
I have to agree with Margie. These are all important things and we cannot be left at some later date being told that we cannot do this because it was never mentioned to registrants.
I could live with a much more general statement, but we have been told by the CPH that they need something less vague to put in their policies to registrants.
Although I do not believe there is any merit in pursuing it, I will restate that SOME 3rd party requests are in fact in support of ICANN's mission (those that directly protect the SSR of the DNS) and I believe that the statement that we were conflating 3rd-party purposes with our own was partially in error.
At 04/03/2020 05:50 PM, Margie Milam wrote:
We support Brianâ€™s proposed Purpose 2 below, and note that without it – theere are many gaps, including:
* Operationalizing and implementing new policies and contract provisions (RDAP, transfers, TM Clearinghouse, etc.)
* Conducting research using the contacts
* Coordinating cyber-attack responses such as Conficker & other cyber attacks
* Publishing Accuracy Reporting System (ARS) reports
* Conducting testing of new registrar/registries to ensure that the WHOIS systems work in the manner required by the contract
* Implementing & testing escrow deposits with 3rd party escrow providers
All the best,
Margie, Mark & Steve
On behalf of the BC
IP Enforcement & DNS Policy Lead | Facebook Legal
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From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of "King, Brian via Gnso-epdp-team" <gnso-epdp-team at icann.org>
Reply-To: "brian.kingATmarkmonitor.com" <brian.king at markmonitor.com>
Date: Wednesday, March 4, 2020 at 10:12 AM
To: "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
Subject: [Gnso-epdp-team] Purpose 2
Following last weekâ€™s conversation about some EPDP membersâ€™ desire to have a bit more specificity in Purpose 2 (the irony of which is not lost on the IPC ), I propose the below:
Contributing to the maintenance of the security, stability, and resiliency of the Domain Name System in accordance with ICANNâ€™s mission, specifically â€œmaintenance of and access to accurate and up-to-date information concerning registered names and name servers.â€ (ICANN Bylaws, Annex G-1; ICANN Bylaws, Annex G-2)
Brian J. King
Director of Internet Policy and Industry Affairs
T +1 443 761 3726
Protecting companies and consumers in a digital world
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