[Gnso-ppsai-pdp-wg] Final Report with updated recommendations, and next steps
Stephanie Perrin
stephanie.perrin at mail.utoronto.ca
Mon Nov 30 22:42:41 UTC 2015
I agree, seems reasonable to me.
Stephanie
On 2015-11-30 16:25, Kathy Kleiman wrote:
> This wording makes sense to me. Customers learn of the
> de-accreditation when it is made final. They then have 30 days to find
> another Provider, relocate their proxy/privacy registration and
> protect their privacy. That sounds right and I support Darcy's edit.
>
> Best, Kathy
>
> On 11/30/2015 4:10 PM, Darcy Southwell wrote:
>> 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.”
>>
>>
>> From: <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 30, 2015 at 12:57 PM
>> To: Volker Greimann <vgreimann at key-systems.net
>> <mailto:vgreimann at key-systems.net>>, "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
>>
>> Perhaps one way to reformulate this to capture Darcy’s suggestion is
>> to say “practicable ways in which customers may be notified as soon
>> as possible after a breach notice is issued and well before it
>> becomes effective.”
>>
>> *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 <mailto: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. 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> 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
>> <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>
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>>
>>
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>>
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>> Mit freundlichen Grüßen,
>> Volker A. Greimann
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>
>
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