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

Darcy Southwell darcy.southwell at endurance.com
Mon Nov 30 21:10:22 UTC 2015 

My suggestion is more along the lines of this (changes in red):

"Principle 1: *** the WG recommends that ICANN explore practicable ways in
which customers may be notified during the breach notice process (or its
equivalent) once ICANN issues a termination of accreditation notice but
before the de-accreditation becomes effective.  The WG recommends that
de-accreditation become effective 30 days after notice of termination.²


From:  <gnso-ppsai-pdp-wg-bounces at icann.org> on behalf of "Metalitz, Steven"
<met at msk.com>
Date:  Monday, November 30, 2015 at 12:57 PM
To:  Volker Greimann <vgreimann at key-systems.net>,
"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

Perhaps one way to reformulate this to capture Darcy¹s suggestion is to say
³practicable ways in which customers may be notified as soon as possible
after a breach notice is issued and well before it becomes effective.²

 

From: gnso-ppsai-pdp-wg-bounces at icann.org
[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Volker Greimann
Sent: Monday, November 30, 2015 12:31 PM
To: gnso-ppsai-pdp-wg at icann.org
Subject: Re: [Gnso-ppsai-pdp-wg] Final Report with updated recommendations,
and next steps

 

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.
> 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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