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

Volker Greimann vgreimann at key-systems.net
Mon Nov 30 17:31:06 UTC 2015


That sounds reasonable. The notice period could be seen as similar to 
the suspension period for registrars currently in place where a 
registrar is no langer able to accept new registrations or transfers, 
but can still serve its existing customers.

I support the suggested change of moving the notice out of the breach 
notice period.

Volker


Am 30.11.2015 um 17:38 schrieb Darcy Southwell:
> All,
>
> I have some concerns about the language contained in Principle 1 on 
> page 17.  It’s certainly important the WG’s recommendations focus on 
> minimizing any risks of exposing private customer data during the 
> de-accreditation process.  However, notifying customers “during the 
> breach notice process (or its equivalent)” seems problematic.  This 
> assumes every P/P provider that receives a breach notice will end up 
> de-accredited.  That’s clearly not the case in the current registrar 
> breach process, and it’s 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 that’s ever done something in violation of the accreditation 
> contract – and that’s 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 30–day period 
> between the termination notice and termination effective date, there 
> is ample time to notify customers.
>
> Look forward to tomorrow’s meeting.
>
> Thanks,
> Darcy
>
> From: <gnso-ppsai-pdp-wg-bounces at icann.org 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>> on behalf of "Metalitz, 
> Steven" <met at msk.com <mailto:met at msk.com>>
> Date: Monday, November 23, 2015 at 1:33 PM
> To: 'Mary Wong' <mary.wong at icann.org <mailto:mary.wong at icann.org>>, 
> "gnso-ppsai-pdp-wg at icann.org <mailto:gnso-ppsai-pdp-wg at icann.org>" 
> <gnso-ppsai-pdp-wg at icann.org <mailto: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 week’s 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> 
> [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 <mailto: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 WG’s 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. P_lease 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 WG’s further
>     agreement in Dublin about “importing” 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
>     WG’s 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 <mailto:mary.wong at icann.org>
>
> _______________________________________________ Gnso-ppsai-pdp-wg 
> mailing list 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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-- 
Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.

Mit freundlichen Grüßen,

Volker A. Greimann
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