[Gnso-epdp-team] SSAD as a means of publishing non-personal data

Volker Greimann vgreimann at key-systems.net
Thu Apr 22 13:10:58 UTC 2021

1. SSAD was approved by the PDPD consensus, by the GNSO council with
sufficient votes and by the board. It will exist. If it does not, we will
be forced back to the drawing board for another couple of years and the
status quo will persist. If you prefer that over SSAD, go ahead and kill

2. This would be questions for the implementation phase, but maybe some
guidance would be helpful to put people here at ease. I do not think there
needs to be authentication for basic SSAD access. The terms currently in
place for domain name registration are fully sufficient for that access
level: Validation of format of the data, verification of email address,
valid payment method. This would be my personal view.

3. As this access level would require significantly lower barriers than
full access, fees for this type of requests could be lower as well. For
comparison, requests for data from the German trade register cost medium
one-digit EUR amounts per request. The added benefit is that this common
type of request could carry a base cost load for the system, allowing lower
overall costs for all requests. Only leaving SSAD for personal data would
on the other hand drive up costs. The more we include in SSAD, the better
the price structure should be.

4. If we do need another PDP (not convinced that we do) this could be
pre-determined and targeted. If we all agree now that we want this to
happen, debate the specifics before the PDP is launched, the time needed
for the actual PDP could be minimal.

5. To the contrary, there are a myrad of advantages: Use of existing
infrastructure, lower overall SSAD fees, better protection of registrants,
access controls, prevention of harvesting for illicit purposes (SPAM,
phishing, etc) , requestor ID, reduced risk for CPs, no need to build out
yet another system for a sub-category of domain names, no data transfer
liability issues, etc. The list goes on and on...

Volker A. Greimann
General Counsel and Policy Manager

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On Thu, Apr 22, 2021 at 8:02 AM Alan Greenberg via Gnso-epdp-team <
gnso-epdp-team at icann.org> wrote:

> There continues to be discussion regarding using the SSAD as a means
> of "publishing" non-personal data.
> I believe that this discussion is a distraction that takes focus from
> what we should be working on. I say this for the following reason.
> 1. The SSAD does not exist, it may never exist, and if the Board does
> approve it, it will likely take several years to implement (remember
> we are 2 years into the implementation of Phase 1, and there is no
> centralized hardware/software to design and implement for that).
> 2. Although we specified that anyone may be accredited, it is not at
> all clear the amount of time it will take, nor what fee might be
> charged. And unless the system allows accreditation without
> authenticating the identity, this precludes anonymous queries.
> 3. We specified that the SSAD must be self-funding and that the users
> must pay for its operating costs. Are those in favour of using the
> SSAD for public data publishing proposing fees for such requests, or
> no fees, and if the latter, who will pay for this usage?
> 4. There are multiple details of Phase 2 Recommendation 8 for
> Contracted Party Authorization that simply make no sense in this
> case, yet are part of the approved policy. And changing that policy
> requires a PDP.
> 5. There does not seem to be any benefit of routing public-data
> requests through the SSAD with its myriad rules, regulations and
> processes when a vanilla RDAP server will suffice.
> Alan
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