[Gnso-epdp-team] Proposed Small Team on Rec #3 and Standardized Data Element Values
Volker Greimann
vgreimann at key-systems.net
Thu Aug 19 10:14:28 UTC 2021
Hi all,
the preference in the RRSG is always to use what is already present, so
using the already defined KIND field would be preferable to inventing
something new. So looking at Steve's proposals, the one element approach
would be preferable to the two element approach.
That said, I cannot exclude the possibility that some CPs may be using this
field already for some internal purposes and repurposing it may cause
difficulties in implementation for that party.
We still disagree that there is need to differentiate between entity types
and contend that it would be fully sufficient to differentiate by data
type, so we would would reduce the fields to:
000001 Unspecified. The registrant has not indicated whether the data set
contains personal information of a natural person
000010 Personal Data: Registrant has indicated that personal information of
natural person is contained in data set
000100 No Personal Data: Registrant has indicated that no personal
information of natural person is contained in data set
Further optional granularity is could be possible with regard to specific
data elements where the registrant has indicated the presence of personal
information:
000011 Name field: Registrant has indicated that no personal information of
a natural person is contained in "name" field
000012 Street Field: Registrant has indicated that no personal information
of a natural person is contained in "street" field
...
00001x email address field: Registrant has indicated that no personal
information of a natural person is contained in "email" field
This would allow a CP choosing to offer such granularity to allow a
customer to mark selected fields as not containing personal information
similar to how the EPP protocol currently already allows selective
publication (even though most CPs do not make use of that functionality).
The registrant would be able to declare which fields contain no personal
information and should be handled as such in accordance with the disclosure
rules of the Registrar.
I also note that there is strong resistance within the CP community against
the inclusion of any such field, optional or non-optional. The use of any
such field should remain optional to offer and implement. To have any
chance of agreement to the optional use of this field for this purpose and
the inclusion of such definitions, I believe that full consensus on this
optionality by all SGs would be required, e.g. we would need the full
consensus of IPC, BC, ALAC, GAC and SSAC - no "backsies" on council level
either. I further believe that it will be difficult for contracted parties
further removed from the registrant (such as registries) to rely on such
declarations and this would therefore likely be a registrar-RDAP-only field
(although exceptions could be possible for example in .BRAND scenarios).
I do see that this would make the registrar output potentially more
"valuable" if the registrar opts-in to the use of this field, which raises
once more the issue of thick vs thin, but that is another debate for
another time.
The above are my personal thoughts. Due to vacation of many of our members,
I cannot say how far this view is shared by other members of the team, or
the registrar community at large.
--
Volker A. Greimann
General Counsel and Policy Manager
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On Thu, Aug 19, 2021 at 5:15 AM Steve Crocker via Gnso-epdp-team <
gnso-epdp-team at icann.org> wrote:
> Keith, et al,
>
> Attached is my suggestion regarding capturing both the registrant's legal
> status (KIND) and whether the registrant data contains personal information.
>
> Thanks,
>
> Steve
>
>
> On Wed, Aug 18, 2021 at 6:03 PM Steve Crocker <steve at shinkuro.com> wrote:
>
>> Excellent! Count me in. I will try to send a short note tonight.
>>
>> Steve
>>
>> Sent from my iPhone
>>
>> On Aug 18, 2021, at 5:03 PM, Drazek, Keith via Gnso-epdp-team <
>> gnso-epdp-team at icann.org> wrote:
>>
>>
>>
>> Hi all,
>>
>>
>>
>> As we work to complete our Final Report, the Leadership team and Staff
>> would like to suggest a very focused bit of additional work related to
>> proposed Rec #3 and the potential standardized data element. This follows
>> from our recent facilitated conversations and plenary discussions
>> concerning the need to better define the values in a such a data element.
>>
>>
>>
>> 1. There appears to be momentum to support a standardized data
>> element that MAY be used by Registrars if they choose to differentiate
>> between legal and natural persons, and/or whether a registration data set
>> contains personal data. That said, based on recent input and discussion,
>> moving this forward to a consensus recommendation appears likely only if
>> the full group agrees that any disclosures or use of the data element(s)
>> would occur within a restricted system such as SSAD.
>>
>>
>>
>> 1. It has also been suggested that the KIND data element within RDAP,
>> which already exists, could be modified to become fit for purpose. Whether
>> it is or not, additional specificity is required on how the data element(s)
>> will achieve the purpose of our policy objective. Without that specificity,
>> the benefit of Recommendation #3 may be difficult to define or implement.
>>
>>
>>
>> 1. Doing this extra work now depends in part on whether we can reach
>> consensus around the development/use of a standardized data element within
>> a restricted system such as SSAD, so that may be a gating question to be
>> answered in short order.
>>
>>
>>
>> *Assignment:*
>>
>>
>>
>> If there is general agreement among the full team that a standardized
>> data element would be used within a restricted system, the small
>> team will develop a proposal that can better inform Recommendation #3 and,
>> if adopted, better inform the parties who would implement it. As such, for
>> the purpose of this very focused work, the topics of transfer of the data
>> element from Registrar to Registry and the publication of data element(s)
>> to a public directory are out of scope. If there’s general agreement to
>> proceed, the proposed specific tasks of the small group are:
>>
>>
>>
>> • Is the KIND RDAP data element fit for purpose of differentiation or
>> the indication of whether the registration data contains personal data?
>>
>> • If not, what data element(s) need to be created?
>>
>> • What are the value types for these data element(s) and its respective
>> definition?
>>
>> • Revision of Recommendation #3 text.
>>
>> • Indication of what ICANN Org must do vs. IETF or other standards
>> bodies.
>>
>>
>>
>> Suggested contributors: I’d like to avoid over-engineering or restricting
>> this small group, but it seems that input from Steve Crocker, Brian King,
>> Volker Greimann, Marc Anderson, Alan Greenberg, and Chris Lewis-Evans would
>> be a great starting point to develop text for full EPDP team consideration.
>> If anyone else has a strong interest in participating, feel free to let me
>> know during Thursday’s plenary call, but we should try to keep it
>> manageable for scheduling purposes. Staff will also support the group’s
>> work.
>>
>>
>>
>> *Suggested Timing:*
>>
>> • 20 Aug or 21 Aug – first small team meeting
>>
>> • 24 Aug – provide update to plenary
>>
>> • 24,25 Aug – additional meetings as necessary; send output to plenary
>>
>> • 26 Aug –
>>
>>
>>
>> Please consider this proposal and come prepared to give initial
>> thoughts/feedback during Thursday’s plenary. There’s some additional
>> context included below.
>>
>>
>>
>> Thanks in advance!
>>
>> Keith
>>
>>
>>
>> *Appendix Contents:*
>>
>> • Brian King’s email 5 Aug 2021
>>
>> • RySG Operational Challenge comment
>>
>> • Steve Crocker Zoom chat comments
>>
>>
>>
>> *Appendix:*
>>
>> *Brian King’s email 5 Aug 2021:*
>>
>> Hi all,
>>
>>
>>
>> I’d like to share some thoughts on how we could leverage the "kind"
>> attribute in RDAP to convey legal vs. natural registrant data.
>>
>>
>>
>> RDAP uses jCard
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc7095&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=_iCyyozPy8O9rDaJOckHD1vV_7nXvvCL0aDn_2xp5ro&e=> (a
>> json version of the vCard
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc6350&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=WznYXurUATL3BHkfO6vaON88WPD_ZFhqgJB87FrOlJk&e=> standard)
>> to convey contact information about individuals and organizations in json
>> formatted RDAP Responses
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc7483&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=va8Ii11hnpWYkmiaLkJl4ohY4ip9Pc6Wj2Hkvioxo1Y&e=>
>> .
>>
>>
>>
>> The vCard
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc6350&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=WznYXurUATL3BHkfO6vaON88WPD_ZFhqgJB87FrOlJk&e=> spec
>> (and thus jCard
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc7095&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=_iCyyozPy8O9rDaJOckHD1vV_7nXvvCL0aDn_2xp5ro&e=>)
>> does not mandate or require the inclusion of “kind”. Its inclusion is
>> optional and if it is not present the kind of “individual” is to be
>> assumed. From the vCard
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc6350&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=WznYXurUATL3BHkfO6vaON88WPD_ZFhqgJB87FrOlJk&e=>
>> spec:
>>
>>
>>
>> *6.1.4*
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc6350-23section-2D6.1.4&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=VDvAoRZVjaPKNzio98DH4h6BYC3xG9ku7zZXUnxoJBo&e=>*.
>> KIND*
>>
>>
>>
>> Purpose: To specify the kind of object the vCard represents.
>>
>>
>>
>> Value type: A single text value.
>>
>>
>>
>> Cardinality: *1 *[Exactly one instance per vCard MAY be present.]*
>>
>>
>>
>> Special notes: The value may be one of the following:
>>
>>
>>
>> *"individual" for a vCard representing a single person or entity.*
>>
>> * This is the default kind of vCard.*
>>
>>
>>
>> "group" for a vCard representing a group of persons or entities.
>>
>> The group's member entities can be other vCards or other types
>>
>> of entities, such as email addresses or web sites. A group
>>
>> vCard will usually contain MEMBER properties to specify the
>>
>> members of the group, but it is not required to. A group vCard
>>
>> without MEMBER properties can be considered an abstract
>>
>> grouping, or one whose members are known empirically (perhaps
>>
>> "IETF Participants" or "Republican U.S. Senators").
>>
>>
>>
>> All properties in a group vCard apply to the group as a whole,
>>
>> and not to any particular MEMBER. For example, an EMAIL
>>
>> property might specify the address of a mailing list associated
>>
>> with the group, and an IMPP property might refer to a group
>>
>> chat room.
>>
>>
>>
>> *"org" for a vCard representing an organization. An organization*
>>
>> * vCard will not (in fact, MUST NOT) contain MEMBER properties,*
>>
>> * and so these are something of a cross between "individual" and*
>>
>> * "group". An organization is a single entity, but not a person.*
>>
>> * It might represent a business or government, a department or*
>>
>> * division within a business or government, a club, an*
>>
>> * association, or the like.*
>>
>>
>>
>> * All properties in an organization vCard apply to the*
>>
>> * organization as a whole, as is the case with a group vCard.*
>>
>> * For example, an EMAIL property might specify the address of a*
>>
>> * contact point for the organization.*
>>
>>
>>
>> "location" for a named geographical place. A location vCard will
>>
>> usually contain a GEO property, but it is not required to. A
>>
>> location vCard without a GEO property can be considered an
>>
>> abstract location, or one whose definition is known empirically
>>
>> (perhaps "New England" or "The Seashore").
>>
>>
>>
>> All properties in a location vCard apply to the location
>>
>> itself, and not with any entity that might exist at that
>>
>> location. For example, in a vCard for an office building, an
>>
>> ADR property might give the mailing address for the building,
>>
>> and a TEL property might specify the telephone number of the
>>
>> receptionist.
>>
>>
>>
>> An x-name. vCards MAY include private or experimental values for
>>
>> KIND. Remember that x-name values are not intended for general
>>
>> use and are unlikely to interoperate.
>>
>>
>>
>> An iana-token. Additional values may be registered with IANA (see
>>
>> Section 10.3.4
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__datatracker.ietf.org_doc_html_rfc6350-23section-2D10.3.4&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=vWjyHE5BqIxOwmSLyN32eSCpw3RFfsm4oK1mfqwYLOI&e=>).
>> A new value's specification document MUST
>>
>> specify which properties make sense for that new kind of vCard
>>
>> and which do not.
>>
>>
>>
>> Implementations MUST support the specific string values defined
>>
>> above. *If this property is absent, "individual" MUST be assumed*
>>
>> * as the default.* If this property is present but the
>>
>> implementation does not understand its value (the value is an
>>
>> x-name or iana-token that the implementation does not support),
>>
>> the implementation SHOULD act in a neutral way, which usually
>>
>> means treating the vCard as though its kind were "individual".
>>
>> The presence of MEMBER properties MAY, however, be taken as an
>>
>> indication that the unknown kind is an extension of "group".
>>
>>
>>
>> ICANN could of course create and mandate a profile that describes how the
>> jCard “kind” value can be used to distinguish between natural
>> (“individual”) and legal (“org”) contacts.
>>
>>
>>
>> If we get pushback to re-using (or overloading) “individual” and “org” to
>> indicate legal and natural, we could use the iana-token extension mechanism
>> defined in the spec. Essentially this would allow us to create two new
>> RDAP specific “kind” values. E.g.
>>
>>
>>
>> "legal" <We would create a definition that would detail what the kind
>>
>> value of “legal” means>
>>
>>
>>
>> "natural" <We would create a definition that would detail what the kind
>>
>> value of “natural” means>
>>
>>
>>
>> This would be accomplished by creating an internet-id and submitting to
>> IANA (IPT) for approval.
>>
>>
>>
>> Lastly, there is an internet-draft being worked on in the “regext”
>> working group in the IETF. The regext working group is where all the RDAP
>> technical specs are defined.
>>
>>
>>
>> This internet-draft, called the RDAP jCard Profile Spec
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__tools.ietf.org_id_draft-2Dharrison-2Dregext-2Drdap-2Djcard-2Dprofile-2D00.html&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=AH7s959LhuGeUQguI2S2cxYVbELvkhki8FKaCuYqBGo&e=>,
>> currently requires the use of kind in all RDAP jCard responses.
>>
>> o “Each jCard MUST contain a "kind" property. The value of that property
>> MUST be "individual", "group", or "org".”
>>
>>
>>
>> Now I don’t know the status of this draft - but it could be used as a
>> “vehicle” to standardize any changes ICANN may need - assuming they were
>> needed.
>>
>> RDAP Response snippets that use “kind = individual”
>>
>>
>>
>> godaddy.com
>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__godaddy.com&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=IpekxI99LmRE_mta6rPGepev0sTuawcVTFI9kuZfVVU&e=> example
>> (registrar = GoDaddy)
>>
>> "entities": [
>>
>> {
>>
>> "objectClassName": "entity",
>>
>> "handle": "1",
>>
>> "vcardArray": [
>>
>> "vcard",
>>
>> [
>>
>> [
>>
>> "version",
>>
>> {},
>>
>> "text",
>>
>> "4.0"
>>
>> ],
>>
>> [
>>
>> * "kind",*
>>
>> * {},*
>>
>> * "text",*
>>
>> * "individual"*
>>
>> ],
>>
>> [
>>
>> "org",
>>
>> {
>>
>> "type": "work"
>>
>> },
>>
>> "text",
>>
>> "Go Daddy Operating Company, LLC"
>>
>> ],
>>
>> [
>>
>> "adr",
>>
>> {},
>>
>> "text",
>>
>> [
>>
>> "",
>>
>> "",
>>
>> "",
>>
>> "",
>>
>> "Arizona",
>>
>> "",
>>
>> "United States"
>>
>> ]
>>
>> ]
>>
>> ]
>>
>> ],
>>
>> "roles": [
>>
>> "registrant"
>>
>> ],
>>
>> "events": [
>>
>> {
>>
>> "eventAction": "last update",
>>
>> "eventDate": "2021-06-22T11:49:32Z"
>>
>> }
>>
>> ],
>>
>> "remarks": [
>>
>> {
>>
>> "title": "REDACTED FOR PRIVACY",
>>
>> "type": "object truncated due to authorization",
>>
>> "description": [
>>
>> "Some of the data in this object has been removed."
>>
>> ]
>>
>> }
>>
>> ]
>>
>> },
>>
>>
>>
>> namecheap.com
>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__namecheap.com&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=FSHWJZUJ53p9d6k9OgEGc8lhNOSZElpBgI8TCK2L_tM&e=> example
>> (registrar = eNom)
>>
>>
>>
>> "entities": [
>>
>> {
>>
>> "objectClassName": "entity",
>>
>> "roles": [
>>
>> "registrant"
>>
>> ],
>>
>> "vcardArray": [
>>
>> "vcard",
>>
>> [
>>
>> [
>>
>> "version",
>>
>> {},
>>
>> "text",
>>
>> "4.0"
>>
>> ],
>>
>> [
>>
>> *"kind",*
>>
>> * {},*
>>
>> * "text",*
>>
>> * "individual"*
>>
>> ],
>>
>> [
>>
>> "lang",
>>
>> {},
>>
>> "language-tag",
>>
>> "en"
>>
>> ],
>>
>> [
>>
>> "adr",
>>
>> {},
>>
>> "text",
>>
>> [
>>
>> "",
>>
>> "",
>>
>> "",
>>
>> "",
>>
>> "AZ",
>>
>> "",
>>
>> "US"
>>
>> ]
>>
>> ],
>>
>> [
>>
>> "contact-uri",
>>
>> {},
>>
>> "uri",
>>
>> "
>> https://tieredaccess.com/contact/ccfaafca-b98c-4a8f-8746-bdaa321c628d
>> <https://urldefense.proofpoint.com/v2/url?u=https-3A__tieredaccess.com_contact_ccfaafca-2Db98c-2D4a8f-2D8746-2Dbdaa321c628d&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ZWAa2OqgTmi7qj2a3LdkCJBk2FgS_bjvOE25EF5aNqc&s=sODG-xyeBvBKzfJnJHIuAIblUNvbBZ9Nfrrc9bzL5lo&e=>
>> "
>>
>> ]
>>
>> ]
>>
>> ],
>>
>> "remarks": [
>>
>> {
>>
>> "title": "REDACTED FOR PRIVACY",
>>
>> "description": "Some of the data in this object has been
>> removed",
>>
>> "type": "object redacted due to authorization"
>>
>> }
>>
>> ]
>>
>> },
>>
>>
>>
>>
>>
>> *RySG Response on Kind Data Element:*
>>
>> *RDAP “kind” element*
>>
>> • The “kind” element isn’t actually an RDAP element, it’s a vcard
>> element (which is a different standard that has been incorporated into the
>> RDAP specification).
>>
>> • The vcard “kind” element isn’t a great fit for differentiating between
>> data of legal and natural persons registrations. The possible values of
>> “group, “org”, “individual” or “location” are not defined with GDPR or data
>> protection in mind and leveraging them here would be a bit of a square
>> peg/round hole.
>>
>> • Each RDAP response contains multiple vcard elements (not just one for
>> the entire domain lookup). In addition to a vcard for each domain contact,
>> the registrar specific data is returned as part of a vcard. The abuse
>> contact email and abuse contact phone data are both also returned as
>> separate vcards.
>>
>> • The vcard specification has not been a good fit for domain RDAP
>> responses and there is an effort underway to replace vcard with a different
>> standard (possibly jcard).
>>
>>
>>
>>
>>
>> *Steve Crocker from 17 Aug 2021 Zoom Chat:*
>>
>> • 01:23:43Steve Crocker, SSAC:If the kind data element is going to be
>> expanded to include additional details of legal persons, the number of
>> possibilities expands a bit. It’s manageable but is a bit more than one
>> might first think. The possible responses to the kind question become:
>>
>> • 01:23:51Steve Crocker, SSAC:Natural
>>
>> • 01:24:12Steve Crocker, SSAC:Legal with personal data
>>
>> • 01:24:19Steve Crocker, SSAC:Legal without personal data
>>
>> • 01:24:36Steve Crocker, SSAC:Legal without specification as to
>> whether it contains personal data
>>
>> • 01:24:50Steve Crocker, SSAC:Unspecified
>>
>> • 01:25:29Steve Crocker, SSAC:In addition to these five responses,
>> there also has to be a way of indicating the lack of data, e.g. if the
>> question hasn’t been asked.
>>
>> • 01:26:19Steve Crocker, SSAC:In practice, this might create a bit of
>> confusion. For example, the registrant might have a hard time
>> distinguishing whether to answer “natural” vs “legal with personal”
>>
>> • 01:27:57Steve Crocker, SSAC:An alternative approach is to use two
>> distinct data elements, one for Natural/Legal/Unspecific and a separate one
>> for Personal/NoPersonal/Unspecified. This approach would also be confusing
>> to some.
>>
>> • 01:27:59Steve Crocker, SSAC:I'M neutral as to which of these
>> approaches is chosen. Both will work and both will be confusing to some.
>> And either will be useful.
>>
>>
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