[Gnso-ppsai-pdp-wg] FW: Draft Grouping of Charter Questions - some edits
Volker Greimann
vgreimann at key-systems.net
Wed Jan 8 12:26:52 UTC 2014
Beyond my earlier comments, I noticed that the current set of questions
also leaves a glaring hole with regard to the consequences of the
termination of a p/p service for the service itself, but more seriously
for its customers:
- Should they be transitioned to a new service provider, similar to the
way currently handled for registrar terminations?
- What happens when their registrar(s) are not integrated with the
new provider?
- Where does the new provider get the underlying data?
- Should the underlying data be immediately revealed?
- etc...
This is an important issue that should also be part of the questions
asked here.
Volker
> Hello all,
>
> As promised, I wanted to follow up on Don's and Kathy's proposed edits
> with some additional proposed edits to the input template; these edits
> are in part based on the background I provided earlier. (The letter
> from Don to the SO/AC chair can, perhaps, be edited based on whether
> there is consensus around our proposed edits.) My edits are to Kathy's
> version which is based on Don's edits -- Don, Marika, Kathy, let me
> know if there's a better way I should have done that!
>
> I wanted to briefly explain the rationale for some of these proposed
> edits.
>
> * When an allegation of illegal activity is submitted to the p/p
> service provider, it is important to understand that it may be
> coming from a victim of the crime. We regularly receive and
> process complaints of illegal pharma activity from victims (or
> familiar members, if a victim ends up dead or in the hospital). We
> must remember that in this case, the registrant has the victim's
> personal information -- where they live, their phone number, their
> payment details, and so forth. It is not unheard of that a rogue
> pharma operator -- just to use an example in my area of knowledge
> -- seeks to retailiate or make threats. Accordingly, we have added
> suggested questions to the portion asking for input as to whether
> the p/p service provider should be required to relay the
> allegation to the registrant, since standard practices should make
> allowances for the fact that the allegation may come from a victim
> seeking redress or additional information. I would argue that the
> relay/disclosure process should appropriately consider how to
> protect both registrants and alleged victims.
> * Similarly, I proposed an additional question regarding whether, if
> disclosure to the registrant is not required, it should be
> permitted even if law enforcement explains that it will jeopardize
> an investigation. The rationale for this is simply that in many
> cases -- in the offline world, as the online world -- disclosing
> this information puts a legitimate investigation at risk.
> * The proposed questions pertaining to jurisdiction are based on the
> problem I identified (and Gema did, as well) in our earlier
> emails. I do feel that the way I've written the questions can be
> clarified and improved, so I welcome anyone who would like to give
> that a shot.
> * Similarly, we propose a question that relates to the other
> business interests controlled by or affiliated with the p/p
> service. To explain this, we have sometimes seen that the criminal
> organization "is" the privacy/proxy service. (Currently, of
> course, there is no accreditation scheme, but the fact remains
> that is what we see, and I am happy to provide examples if need
> be.) To be very specific, we know of circumstances where a rogue
> Internet pharmacy network operates its own "proxy" service, or
> alternatively, the proxy service -- that is, the individuals who
> operate it -- also operates as affiliate marketers for rogue
> networks, using their own privacy/proxy service primarily for
> their own illegal purposes.
>
> Finally, although I unfortunately had to miss the call this morning, I
> believe that some of the comments may have argued that registrars (or,
> ICANN) should not have to address criminal jurisdictional issues (that
> is, multi-jurisdictional complexities). I'd note that banks, credit
> card networks and search engine ad programs regularly have to address
> precisely the same multi-jurisdictional questions relating to criminal
> activity on their platform and do not simply leave it to law
> enforcement. I would argue that there is no reason to consider
> registrars a special case that are for some reason exempt from having
> to address the same issues that companies in the financial and
> advertising sectors have had to address, and have by and large done so
> quite competently. I am confident that the registrar community can
> competently do the same.
>
> Thank you for the opportunity to provide this input, and I welcome any
> suggestions as to how our suggestions can be improved or refined.
>
> John Horton
> President, LegitScript
>
>
> *FollowLegitScript*: LinkedIn
> <http://www.linkedin.com/company/legitscript-com> | Facebook
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>
>
>
> On Tue, Jan 7, 2014 at 7:44 AM, Marika Konings
> <marika.konings at icann.org <mailto:marika.konings at icann.org>> wrote:
>
>
>
> From: Kathy Kleiman <kathy at kathykleiman.com
> <mailto:kathy at kathykleiman.com>>
> Date: Tuesday 7 January 2014 16:38
> To: Marika Konings <marika.konings at icann.org
> <mailto:marika.konings at icann.org>>
> Subject: Fwd: Draft Grouping of Charter Questions - some edits
>
> Hi Marika, could you post this to our working group?
>
>
>
> -------- Original Message --------
> Subject: Draft Grouping of Charter Questions - some edits
> Date: Tue, 07 Jan 2014 10:35:02 -0500
> From: Kathy Kleiman <kathy at kathykleiman.com>
> <mailto:kathy at kathykleiman.com>
> To: gnso-ppsai-pdp-wg at icann.org <mailto:gnso-ppsai-pdp-wg at icann.org>
>
>
>
> Hi All,
> Hopefully you have seen the proposed edits I just to the SG-C
> Input Template (I haven't seen them posted).
>
> Attached here are some inputs to the Draft Grouping of Charter
> Questions - with an organizational-type perspective being added.
> The world is really not just commercial/individual, but truly one
> of commercial, noncommercial and individual (as ICANN has
> organized its non-contracted parties).
>
> For a religious group, political group, hobby group, dissident
> group may be organized as a limited liability company to protect
> the members in case someone falls in the building, but that does
> not nullify the fact that the group is engaged primarily and fully
> in noncommercial speech (as the wide array of members of NCSG show).
>
> Again edits highlighted and hopefully visible. I would like to see
> much more discussion on this issue in our next meeting and over
> the list.
> Best,
> Kathy
>
> :
>>
>> I will miss the first 30 minutes due to another obligation, but
>> will join as soon as I can.
>>
>> *From:*gnso-ppsai-pdp-wg-bounces at icann.org
>> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>
>> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] *On Behalf Of
>> *Marika Konings
>> *Sent:* Monday, January 06, 2014 4:30 AM
>> *To:* gnso-ppsai-pdp-wg at icann.org
>> <mailto:gnso-ppsai-pdp-wg at icann.org>
>> *Subject:* [Gnso-ppsai-pdp-wg] Proposed Agenda - PPSAI PDP WG Meeting
>>
>> Dear All,
>>
>> Please find below the proposed agenda for the next PPSAI PDP WG
>> meeting (Tuesday 7 January at 15.00 UTC).
>>
>> Best regards,
>>
>> Marika
>>
>> *Proposed Agenda -- PPSAI PDP WG Meeting -- 7 January 2013*
>>
>> 1.Roll Call / SOI
>>
>> 2.Review & finalise SG/C Template (see revised version attached)
>>
>> 3.Review & finalise SO/AC Outreach Letter (see revised version
>> attached)
>>
>> 4.Input to EWG Survey (see attached)
>>
>> 5.Update on WG members survey (to participate, please go to
>> https://www.surveymonkey.com/s/86N33WX)
>>
>> 6.Review proposed charter question groupings (see latest version
>> attached)
>>
>> 7.Next steps & confirm next meeting
>>
>>
>>
>> _______________________________________________
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>> Gnso-ppsai-pdp-wg at icann.org <mailto:Gnso-ppsai-pdp-wg at icann.org>https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg
>
>
>
>
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>
>
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--
Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
Mit freundlichen Grüßen,
Volker A. Greimann
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