[Gnso-ppsai-pdp-wg] Final Report with updated recommendations, and next steps

[Darcy Southwell]

All,

I have some concerns about the language contained in Principle 1 on page 17.
It¹s certainly important the WG¹s recommendations focus on minimizing any
risks of exposing private customer data during the de-accreditation process.
However, notifying customers ³during the breach notice process (or its
equivalent)² seems problematic.  This assumes every P/P provider that
receives a breach notice will end up de-accredited.  That¹s clearly not the
case in the current registrar breach process, and it¹s unlikely to be case
with the P/P providers.   Second, there could be significant negative impact
to businesses that receive just one breach notice even though the breach
ends up cured.  The focus of the breach process should not be to penalize
every provider that¹s ever done something in violation of the accreditation
contract ­ and that¹s what this approach implies.

It seems the better approach would be to notify customers somewhere between
the date of the termination notice and the effective date of the
accreditation termination.   If we consider a 30­day period between the
termination notice and termination effective date, there is ample time to
notify customers.  

Look forward to tomorrow¹s meeting.

Thanks,
Darcy

From:  <gnso-ppsai-pdp-wg-bounces at icann.org> on behalf of "Metalitz, Steven"
<met at msk.com>
Date:  Monday, November 23, 2015 at 1:33 PM
To:  'Mary Wong' <mary.wong at icann.org>, "gnso-ppsai-pdp-wg at icann.org"
<gnso-ppsai-pdp-wg at icann.org>
Subject:  Re: [Gnso-ppsai-pdp-wg] Final Report with updated recommendations,
and next steps

Thanks to Mary and her colleagues for generating this final report text.
As noted on last week¹s call, unless it seemed necessary to hold our usual
weekly meeting this week (tomorrow), we would cancel it, in order to give WG
members time to review this text carefully.  The call tomorrow has now been
cancelled, and we urge you to use this week for this review, and for
consultation with the relevant GNSO stakeholder group/constituency, or with
ALAC groups, as appropriate.
The goal of the review and consultation is to identify any mistakes or
ambiguities in this text that would interfere with your ability to respond
to the consensus call.  We urge WG members to bring any such issues up on
the WG list as soon as possible, which will help us in fashioning a
productive agenda for the next WG call on Tuesday December 1.  We have
allocated 90 minutes for this call (beginning at 1430 UTC) to provide
additional time to discuss and resolve any errors or ambiguities identified.
We anticipate that this will be the final WG call before the close of the
consensus call on Monday, December 7.   All expressions of support for the
recommendations of the Final Report, as well as any separate statements
regarding recommendations that you cannot support, will be due at that time.
Thanks to all for your continued efforts as we bring this report across the
finish line! 
 
Steve Metalitz and Graeme Bunton
 
 

From: gnso-ppsai-pdp-wg-bounces at icann.org
[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Mary Wong
Sent: Friday, November 20, 2015 5:39 PM
To: gnso-ppsai-pdp-wg at icann.org
Subject: [Gnso-ppsai-pdp-wg] Final Report with updated recommendations, and
next steps
 

Dear WG members,

 

Please find attached both a clean and marked-up (red-lined) version of the
updated draft Final Report. As the marked-up version may be somewhat
difficult to read given the number of paragraphs moved around, added to or
deleted, we hope the clean version will be helpful in providing a
straightforward read of the proposed final form of the WG recommendations
while the mark-up will show where the changes were made from the draft
report that was circulated on 8 October.

 

As noted in the WG Work Plan, circulation of this updated document opens the
period for the WG¹s consensus call. Following this, in accordance with the
GNSO's WG Guidelines, the WG co-chairs will make a final evaluation of the
consensus support levels and, if necessary, assign specific designations of
such to each individual WG recommendation. Any minority statements must
therefore also be submitted by that time. As noted in the WG Work Plan, the
co-chairs plan to close the consensus call period by Monday 7 December 2015.
Unless determined otherwise as a result of this consensus period, the
recommendations are currently marked as Full Consensus of the WG.

 

For your convenience, the main changes that were made to the draft report
include the following:
* All the substantive changes can be seen in the Executive Summary, which
retain the format and numbering of the recommendations from the earlier
draft. Most of the additional WG conclusions based on discussions subsequent
to 8 October were added to existing numbered recommendations. The relevant
portions of Section V (WG Deliberations) and VII (WG Final Recommendations)
have also been updated to reflect the substantive changes to the numbered WG
recommendations in the Executive Summary. Most of the rest of the report,
and much of even Sections  and VII, remain unchanged from both the Initial
Report (May 2015) and the draft Final Report.
* The final version of the Illustrative Disclosure Framework reflecting the
consensus of Sub Team 3 has been incorporated into the report as Annex B.
Please note that the final recommendation includes only one option for
dispute resolution, which is jurisdiction over arbitration, in language
discussed by the WG and finalized by the Sub Team. There is also a
recommendation for a post-implementation review of the overall framework,
followed by periodic reviews thereafter.
* On transfers, you will see from the recommendations that language has been
added, in particular to #8 and #21. The former makes reference to the effect
of IRTP-C, and the latter ­ in relation to de-accreditation ­ adds a
specific recommendation to the effect that a registrar must lift the
otherwise-required lock under IRTP-C if so requested by the beneficial user
of a proxy registration. This recommendation is based on the narrower option
presented by the Registrar Services team to the WG following the WG call
earlier this week. We have also retained the original WG recommendation that
the next review of the IRTP expressly include consideration of the effect on
P/P registrations.
* On de-accreditation, we have replaced the original specific individual
recommendations with the new set of three general principles recently
reviewed by the WG.
* On definitions, we have included those for a Privacy Service and a Proxy
Service in the list of definitions, and added the most recent version of the
new, supplemental language about registrars not knowingly accepting
registrations from accredited (versus unaccredited) P/P service providers,
and the consequence that an unaccredited provider effectively therefore has
all the responsibility of a Registered Name Holder.
* On LEA, we have added language to reflect the WG¹s further agreement in
Dublin about ³importing² a few critical elements from the Illustrative
Disclosure Framework into a suggestion that these be included in any future
LEA request framework that may be developed.
* In the general recommendation section, we have added recommendations based
on the work of Sub Team 3, as discussed by the WG in Dublin, for an
educational/outreach program and for the periodic provision of aggregated
statistics to ICANN by providers.
* Elsewhere, we have added or edited language, again based on the WG¹s
discussions in Dublin and subsequently, to flesh out or clarify existing
recommendations. Most of these are indicated with a comment box explaining
where the change came from.
Thanks to everyone, especially our co-chairs and the various Sub-Teams, for
facilitating our progress toward a Final Report!

 

Cheers

Mary

 

Mary Wong

Senior Policy Director

Internet Corporation for Assigned Names & Numbers (ICANN)

Telephone: +1 603 574 4889

Email: mary.wong at icann.org

 

 
 
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