[Gnso-epdp-team] Legal/Natural via SSAD

Volker Greimann vgreimann at key-systems.net
Thu Apr 22 19:51:38 UTC 2021

Hi Brian,

I think a lot of the details will still need to be fleshed out, but I see
this proposal as mutually beneficial:- by introducing SSAD light for what
essentially boils down to automatable requests, usage costs would be
significantly driven down for requesters.
I must admit that much of this has not yet been discussed with the
registrar community at large, but I see consensus here as possible, if not

My proposal boils down to:
- automated SSAD disclosures for registration data that has been identified
(in whatever way we ultimately all can agree upon) as either not containing
personal information or as having received the registrants consent for
- lower access requirements for access to such data as risk of disclosure
of personal information is low. (model: German trade register)
- lower fees for accessing an automated-response query (same model)
- lower risk of wrongful disclosure as requestors are known. Law
enforcement may have privileged requester status that would prevent
disclosure of their identity, but would still be auditable within SSAD.
- no need for CPs to build out a separate system, standard SSAD
implementation with automated disclosure elements would be sufficient.

Open questions:
- Criteria for identification of data sets not containing PII (self-ID)
- Criteria by which third parties could see whether automated disclosure is
possible (a: flag in RDAP; b: response to basic query in SSAD that this
disclosure would be automated; c: ???)
- Best road to implementation? Is full PDP needed?

The days of the RDS as an all-you-can-leech source of personal information
are over. This could be the best chance of a reasonable alternative.

I think constructive suggestions on how to improve the model while
preserving its strengths could really bring us all forward.

Volker A. Greimann
General Counsel and Policy Manager

T: +49 6894 9396901
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Key-Systems GmbH is a company registered at the local court of
Saarbruecken, Germany with the registration no. HR B 18835
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On Thu, Apr 22, 2021 at 7:29 PM King, Brian via Gnso-epdp-team <
gnso-epdp-team at icann.org> wrote:

> Hi Volker,
> Hoping to clarify your proposal so we can consider it fully, are you
> proposing to automate SSAD disclosure for domains whose registrants have
> self-designated that the registrant is a legal entity and the RDS data does
> not include personal data (fulfilling Milton’s principle of
> self-designation)?
> *Brian J. King*​
> Head of Policy and Advocacy, Intellectual Property Group
> T +1 443 761 3726​
> *clarivate.com <http://clarivate.com>*​
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