[Gnso-epdp-team] Recommendation on Web Forms

Tue May 25 21:53:23 UTC 2021

Hi Volker,

I deliberately cut off before and after the relevant quote for brevity and to focus on the relevant part of the instructions. The only guardrails around the proposals to be considered in this phase are that they be “specific” and that they provide safeguards against issues B&B flagged.

The web form proposal checks both boxes, and there are no other qualifying criteria around proposals to be considered.

Given that, if folks want to exclude this from the report, the onus is really on the RrSG to come up with some concrete reason why we wouldn’t meet GNSO Council’s expectation “that all the required steps are followed in the consideration of these issues which may include further public comment on an Initial Report and a Final Report that would be considered an addendum to the EPDP Phase 2 Final Report.”

Brian King
He/Him/His
Head of Policy and Advocacy

T +1 443 761 3726
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From: Volker Greimann <vgreimann at key-systems.net>
Sent: Tuesday, May 25, 2021 3:49 PM
To: King, Brian <Brian.King at markmonitor.com>
Cc: gnso-epdp-team at icann.org
Subject: Re: [Gnso-epdp-team] Recommendation on Web Forms

Hi Brian
You conveniently left out half the sentence there. Accidental?
Here it is in its full context:
„ consider specific proposals that provide sufficient safeguards to address issues flagged in the legal memo.“

Stating that the proposals around web forms were flagged in the legal memo is a stretch at best.

Volker

On Tue 25. May 2021 at 20:35, King, Brian via Gnso-epdp-team <gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org>> wrote:
Hi all,

As noted, we are supposed to “consider specific proposals that provide sufficient safeguards…”  The proposal around web forms is such a proposal.

As such, we should include it in the initial report so we can solicit public comments.

Brian King
He/Him/His
Head of Policy and Advocacy

T +1 443 761 3726
Time zone: US Eastern

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From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org<mailto:gnso-epdp-team-bounces at icann.org>> On Behalf Of Sarah Wyld via Gnso-epdp-team
Sent: Tuesday, May 25, 2021 2:00 PM
To: Alan Greenberg <alan.greenberg at mcgill.ca<mailto:alan.greenberg at mcgill.ca>>; Volker Greimann <vgreimann at key-systems.net<mailto:vgreimann at key-systems.net>>
Cc: gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Recommendation on Web Forms

Hello all,

The Instructions for this phase were clear:

b) In relation to feasibility of unique contacts to have a uniform anonymized email address, the EPDP Team is expected to review the legal guidance and consider specific proposals that provide sufficient safeguards to address issues flagged in the legal memo. Groups that requested additional time to consider this topic, which include ALAC, GAC and SSAC, will be responsible to come forward with concrete proposals to address this topic. This consideration is expected to address:
i. Whether or not unique contacts to have a uniform anonymized email address is feasible, and if feasible, whether it should be a requirement.
ii. If feasible, but not a requirement, what guidance, if any, can be provided to Contracted Parties who may want to implement uniform anonymized email addresses. For clarity, the GNSO Council is not directing any particular outcome on either topic, but as manager of the PDP, it is sharing its expectations with regards to which questions are expected to be addressed as part of the EPDP Team’s deliberations. Consistent with the PDP Manual, the GNSO Council does expect that all the required steps are followed in the consideration of these issues which may include further public comment on an Initial Report and a Final Report that would be considered an addendum to the EPDP Phase 2 Final Report.

Web form requirements are not considered here, and the relevant recommendation is not described as open for review. Web form requirements are out of scope for this EPDP Phase 2a.

--

Sarah Wyld, CIPP/E

Policy & Privacy Manager

Pronouns: she/her

swyld at tucows.com<mailto:swyld at tucows.com>

+1.416 535 0123 Ext. 1392

[cid:image001.png at 01D7518C.CC9CFA30]

From: Alan Greenberg via Gnso-epdp-team<mailto:gnso-epdp-team at icann.org>
Sent: May 25, 2021 1:56 PM
To: Volker Greimann<mailto:vgreimann at key-systems.net>
Cc: gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Recommendation on Web Forms

Volker, if you and the other registrars agree to be bound by contractual limitations of what a web form should contain as set by the Phase 1 IRT (presuming it agrees to take this on), I would consider it. I have not heard such agreements.

Phase 2a is discussing email contact to registrants. That is Phase 1 Recommendation 13. This is not expanding the scope of this PDP phase.

Alan

At 2021-05-25 01:22 PM, Volker Greimann wrote:
Hi Alan,

you are correct: This should be addressed as part of the P1 IRT, not this group.  We cannot willy-nilly expand the scope of a PDP. Or should we ask to include some transfer issues relating to registration data next? Or change the ICANN bylaws?
--
Volker A. Greimann
General Counsel and Policy Manager
KEY-SYSTEMS GMBH

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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 Tue, May 25, 2021 at 6:45 PM Alan Greenberg <alan.greenberg at mcgill.ca<mailto:alan.greenberg at mcgill.ca> > wrote:
Volker et al,
The Chair suggested that this issue should be addressed, but by the Phase 1 IRT.  I believe that he was correct in that the issue does need to be addressed but do not believe that is a real possibility, since the Phase 1 policy did not imply and web form content requirements.
So that leaves us with needing to take some other action to remedy the Phase 1 recommendation that is not working.
Unless you are recommending starting a new PDP just to address this issue, this is a way to finesse it. We include it in our report and solicit input. And of course discuss it following the comment period.
If indeed the instructions from the GNSO Council need to be changed (which I do not believe), that could happen after the public comment period.
This Phase 2a DOES have the mandate to require some form of email address be used. So we ARE discussing a change to Recommendation 13. If we choose NOT to do that, we need to make sure the remaining policy is viable. So I believe this recommendation is indeed in scope!
Alan
At 2021-05-25 12:30 PM, Volker Greimann wrote:
Hi Laureen,
yes, we did discuss it and always returned to the point that it was out of scope for our group. While I understand the desire to have something on webforms included, discussion was rather one-sided due to the scope. I understand from other registrars that there are many issues with input fields as part of the webforms and they have chosen the format of their forms for a reason.
Best,
--
Volker A. Greimann
General Counsel and Policy Manager
KEY-SYSTEMS GMBH
T: +49 6894 9396901
M: +49 6894 9396851
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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
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.
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On Tue, May 25, 2021 at 6:17 PM Kapin, Laureen <LKAPIN at ftc.gov<mailto:LKAPIN at ftc.gov>> wrote:
To be fair, this issue has been discussed many times during our meetings.  This recommendation merely captures what has already been proposed by certain SGs. Hence I suggest that it be included for the purpose of soliciting public comments.

Laureen Kapin

Acting Assistant Director
Division of Consumer Response and Operations
Bureau of Consumer Protection
Federal Trade Commission

From: Gnso-epdp-team < gnso-epdp-team-bounces at icann.org<mailto:gnso-epdp-team-bounces at icann.org>> On Behalf Of Volker Greimann via Gnso-epdp-team
Sent: Tuesday, May 25, 2021 11:56 AM
To: Alan Greenberg <alan.greenberg at mcgill.ca<mailto:alan.greenberg at mcgill.ca> >
Cc: EPDP <gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org> >
Subject: Re: [Gnso-epdp-team] Recommendation on Web Forms

Hi,

I think it is not appropriate to introduce a new recommendation at the last minute that has not been deliberated and seems to me to be out of scope of this WG. While I have no objection to the content of this recommendation, and KS has already implemented its webforms in a similar manner, I think the process concern must prevail here.

Best,

--
Volker A. Greimann
General Counsel and Policy Manager
KEY-SYSTEMS GMBH
T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
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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
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 Tue, May 25, 2021 at 2:45 AM Alan Greenberg via Gnso-epdp-team <gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org> > wrote:
Unfortunately, Mark and I did not get this in prior to the Friday deadline, but we still believe that it is crucial to include in the Initial Report.
Although some form of email address is a far preferable solution for many on this EPDP, it appears that this will not be a recommendation.
As it stands, the EPDP Recommendation #13 which is supposed to facilitate communications with the registrant does not achieve its goal. Many registrars are using web forms, and in many cases, they are effectively useless. As an example, one common example is a form that simply lets the requestor select one of three messages (Domain name or content is being used in malware, or for spam or abuse; Domain name or content is infringing on a trademark or violating local laws or regulations; or Research or other purpose).
It has been suggested that this matter be referred to the Phase 1 IRT, but without a recommendation saying that the policy may set web form content, there is no way for the IRT to establish such enforceable rules.
Accordingly, the Initial Report must include a new Recommendation:
Recommendation
The Phase 1 Recommendation 13 should be amended to include:  Should a Registrar choose to use a web form, that form must allow at the requester to specify the Subject of the email to be send (up to 64 characters) and a free-form text message of up to 512 characters to be included in the communication to the registrant.
Alan & Mark
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Volker A. Greimann
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KEY-SYSTEMS GMBH

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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
CEO: Oliver Fries and Robert Birkner

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