[Gnso-epdp-team] SSAD as a means of publishing non-personal data
vgreimann at key-systems.net
Thu Apr 22 14:16:08 UTC 2021
And just for clarity: RDAP should still maintain contactibility.
Volker A. Greimann
General Counsel and Policy Manager
T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
Key-Systems GmbH is a company registered at the local court of
Saarbruecken, Germany with the registration no. HR B 18835
CEO: Oliver Fries and Robert Birkner
Part of the CentralNic Group PLC (LON: CNIC) a company registered in
England and Wales with company number 8576358.
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On Thu, Apr 22, 2021 at 4:02 PM Alan Greenberg <alan.greenberg at mcgill.ca>
> At 2021-04-22 09:10 AM, Volker Greimann wrote:
> 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
> This is not about my trying to kill the SSAD. At this point, the Board
> needs to make a decision, and presumably it will not just blindly
> rubber-stamp the GNSO recommendations. And iyou are not addressing
> proposing a solution that is at best several years out to
> 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.
> OK, so you are proposing a fee-based system for such requests.
> 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.
> Fine. Adding several more years...
> 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
> *KEY-SYSTEMS GMBH*
> T: +49 6894 9396901
> M: +49 6894 9396851
> F: +49 6894 9396851
> W: www.key-systems.net
> Key-Systems GmbH is a company registered at the local court of
> Saarbruecken, Germany with the registration no. HR B 18835
> CEO: Oliver Fries and Robert Birkner
> Part of the CentralNic Group PLC (LON: CNIC) a company registered in
> England and Wales with company number 8576358.
> This email and any files transmitted are confidential and intended only
> for the person(s) directly addressed. If you are not the intended
> recipient, any use, copying, transmission, distribution, or other forms of
> dissemination is strictly prohibited. If you have received this email in
> error, please notify the sender immediately and permanently delete this
> email with any files that may be attached.
> 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.
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