[gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose

Fri Oct 7 19:59:37 UTC 2016

I’m afraid I disagree, Richard, with the notion that "You can’t contact someone if the contact information is inaccurate." Two values can be different, unambiguous, and allow you to contact someone, but strictly speaking inaccurate.

For instance, the data values Myanmar and Burma may both refer to the same country; likewise, the data values Greenwich and Greenwich Village may refer to the same city or neighbourhood. However, the recording of the values is inconsistent.

I am sure that any human being looking at these values would have no trouble determining the country or city, but inconsistent values cannot easily be aggregated and compared. I imagine this would cause issues if the RDS was required to take a value and to correlate/compare it to a field in a secondary source of information (how else would we be able to verify a field as accurate? Surely we are not expecting any human verification?) - but I think this is a conversation for another time.

Best wishes,

Ayden Férdeline
[linkedin.com/in/ferdeline](http://www.linkedin.com/in/ferdeline)

-------- Original Message --------
Subject: Re: [gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose
Local Time: 7 October 2016 7:20 PM
UTC Time: 7 October 2016 18:20
From: rleaning at ripe.net
To: Greg Shatan <gregshatanipc at gmail.com>
gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org>

Thats Greg for articulating it so well.

all i was going to say was -

'You can’t contact someone if the contact information is inaccurate’

So i can’t see how you can split the two.

Richard Leaning
External Relations
RIPE NCC

On 7 Oct 2016, at 17:21, Greg Shatan <gregshatanipc at gmail.com> wrote:

It might be useful to bring in the findings of the WHOIS review team on this point. There have been multiple discussions of contactability and accuracy in various ICANN groups.

We don't need to choose between "accuracy" and "contactability" to have this discussion. Quite the opposite. These are related concepts and our discussion needs to consider both concepts. Contactability can be correlated to "functional accuracy" and also to certain amount of "fault tolerance" in the data. Inaccuracy in some fields is highly detrimental to contactability, in others not so much. Sometimes a certain combination of inaccuracies is fatal to contactability. In other words, contactability informs the discussion of accuracy, and vice versa.

Greg

On Fri, Oct 7, 2016 at 10:13 AM, Stephanie Perrin <stephanie.perrin at mail.utoronto.ca> wrote:

Indeed, I think we should talk about contactable, not "accurate". This was the result of similar discussions of the WHOIS review team, as I understand it, accuracy was defined as contactable. It makes sense to me. I realize that others want more data and more accuracy, but that is their goal, not necessarily the goal of this pdp. The goal of privacy advocates, or those who wish to see data protection law implemented (and I do realize we are few in number) is to minimize the collection of information to what is necessary.

Stephanie

On 2016-10-07 08:27, Michele Neylon - Blacknight wrote:

Stephanie

Here’s one we run into all the time:

A lot of our clients in Northern Ireland do not view themselves as being part of the UK, so they’ll choose to list their country as “Ireland’.

Is the data they supply “bad”? Strictly speaking yes

Are they still reachable? Of course they are.

Regards

Michele

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From: [<gnso-rds-pdp-wg-bounces at icann.org>](mailto:gnso-rds-pdp-wg-bounces at icann.org) on behalf of Stephanie Perrin [<stephanie.perrin at mail.utoronto.ca>](mailto:stephanie.perrin at mail.utoronto.ca)
Date: Friday 7 October 2016 at 00:42
To: Mark Svancarek [<marksv at microsoft.com>](mailto:marksv at microsoft.com), ["gnso-rds-pdp-wg at icann.org"](mailto:gnso-rds-pdp-wg at icann.org) [<gnso-rds-pdp-wg at icann.org>](mailto:gnso-rds-pdp-wg at icann.org)
Subject: Re: [gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose

Not at all, ordinary people make mistakes all the time. However, rarely would this kind of mistake render the person/organization un-contactable, which it seems to me is the evil we are trying to avoid with bad data. On the other hand, criminals have a goal of being untraceable, so will continue to make sure they are not located, right?

SP

On 2016-10-06 19:20, Mark Svancarek wrote:

There seems to be a presumption that bad data is caused entirely by bad people.

Do we actually have data showing which fraction of bad data is created with criminal intent, and which fraction is just people being lazy or careless and then never being held accountable by the data actually being verified?

[ ]

From: gnso-rds-pdp-wg-bounces at icann.org [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of Stephanie Perrin
Sent: Thursday, October 6, 2016 3:09 PM
To: gnso-rds-pdp-wg at icann.org
Subject: Re: [gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose

I agree with those pushing back on including a commitment to accuracy in this statement of purpose. I think there are a number of sound reasons for this. Those of us who push back are not advocating for bad data, that would be silly. What we are addressing is the futility of attempting to get the criminal element to put good data in their registration data. If we force them, we drive ID theft. Here are a few of my reasons:

1. Governments actually do not usually invest taxpayers money verifying citizen data, they provide penalties for having inaccurate data and leave it at that. Verifying address and phone number, given the mobility of the population in the countries I am familiar with from my past government service (US, Canada, Australia, New Zealand, and UK) is expensive and there is very little way to enforce it. This being the case, why would we force ICANN to do this? The cost inevitably would fall on the Registrars and registries, and be passed on to the end users.

2. As mentioned above, any pressure to improve data quality can hardly be expected to get criminals to give their accurate data, it will drive them to steal good data.

3. The vast majority of people are actually honest. I do realize that there is a high volume of cybercrime, but penalizing the majority of end users for the actions of a few (even if those actions result in a high volume of phishing and malware etc) is not good policy. There are other ways to catch and dump bad domains. Prosecution of malfeasant registrants remains a problem, but frankly how many can be prosecuted across borders anyway?

4. We do have questions about accuracy that we need to address, according to our charter. The purpose of this purpose statement is to boil down our business requirements for the activity in which we are engaged. While many actors want more accurate data, how to get that accuracy is so open to question that I regard its inclusion in the statement of purpose as setting impossible goals. I would be happy to revise this sentence as follows:

To enable release of accurate gTLD registration data that may not otherwise be publicly available, under specific and explicit policy-defined conditions Change to

To enable release of gTLD registration data that may not otherwise be publicly available under specific conditions defined by policy, and to develop mechanisms to encourage greater accuracy of data.

Stephanie Perrin

On 2016-10-06 16:48, Chris Pelling wrote:

Hi Nick,

I would actually concur with Volker. I see your point but, can I ask a question, the data collected cannot be proven to any certainty because we have nothing as the registry/registrar community to "check" it against. Simply checking say the address against a city, against a State, against a postal/zip code then country isnt proving the registrant data is correct, its simply proving that the registrant can open a phone book and pick an address out.

Until tools are created to prove that registrant is actually at address X, accuracy is a rather moot point.

I agree with your point about law enforcement and bad data being a cost to the public purse, but until the governments can get together and work out a solution for the data to be verified there is little anyone can do.

Registrant giving fake address = bad data

Registrant giving correct address of neighbour = bad data

Registrant giving old address where previously lived = bad data - but at least it could be validated against old correct data and cross checked

This list could be endless :

Registrant giving correct data = good, verifiable. Maybe the governments can work out a solution to being able to verify their citizens data.

I would love to find a solution that is workable and commercially viable, the governments and LEA can then use the data with some surety to its worthiness - although this is a totally separate topic, I would like to sit down and discuss it further - the governments getting together and helping this work.

Just a thought.

Kind regards,

Chris

------

From: "Nick Shorey" [<nick.shorey at culture.gov.uk>](mailto:nick.shorey at culture.gov.uk)
To: "Volker Greimann" [<vgreimann at key-systems.net>](mailto:vgreimann at key-systems.net)
Cc: "gnso-rds-pdp-wg" [<gnso-rds-pdp-wg at icann.org>](mailto:gnso-rds-pdp-wg at icann.org)
Sent: Thursday, 6 October, 2016 17:38:55
Subject: Re: [gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose

Interesting comments Volker! I guess it's all about the perspective you view it from I suppose. The impact of bad data on law enforcement investigations can also be waste of valuable time and cost. Except the cost comes out of of the public purse...

Nick Shorey BA(Hons) MSc.

Senior Policy Advisor | Global Internet Governance

Department for Culture, Media & Sport

HM Government | United Kingdom

Email: [ nick.shorey at culture.gov.uk](mailto:nick.shorey at culture.gov.uk)

Tel: +44 (0)7710 025 626

Skype: nick.shorey

Twitter: @nickshorey

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On 6 October 2016 at 17:23, Volker Greimann <vgreimann at key-systems.net> wrote:

Hi Greg,

Arguments to the contrary tend to look like a Defense of Bad Data. I can't think of any reasons to defend bad data, unless one wants a bad database.

If you want reasons, here are a few:
1) Cost
2) Waste of valuable time
3) Implementation nightmares
4) No actual standard that applies worldwide
5) Legacy data from legacy sources
6) Customer service nightmare

It's reasonable to strive for perfectly accurate data, but accept that one will never get there. There should be commercially reasonable and proportionate methods to get as close as practically possible.

One can strive for anything, but it may never be achieved, consuming valuable ressources on the way. How many people died trying to reach the south pole, the north pole, the peak of the Matterhorn, before someone made it. While that first one to make is famous now, consider the loss of life and ressources wasted we spent getting there.

We have not (in this group) discussed data migration, but assuming a Garbage In, Garbage Out approach doesn't seem reasonable. Whether all the data is validated before migration, or just validated as part of a normal validation cycle, it needs be validated.

Existing data in is the only feasible solution if you want a manageable transition process.
As for validation by the road, before designing a process we should define who is going to have to implement it, process it, deal with user complaints, pay for it, etc. What is better data worth to those who have to pay for it? Are those that benefit from better data going to finance it (including all associated costs)? If so, let's talk....

Best,
Volker

On Thu, Oct 6, 2016 at 11:00 AM, Carlton Samuels <carlton.samuels at gmail.com> wrote:

+1.

Not to make too fine a point of it. But the EWG was tasked to re-imagine an RDS. If this PDP is tasked to build on the works of EWG maybe it'd be useful to re-visit certain ideas we now hold as verities.

-Carlton

==============================
Carlton A Samuels
Mobile: [ 876-818-1799](tel:876-818-1799)
Strategy, Planning, Governance, Assessment & Turnaround
=============================

On Wed, Oct 5, 2016 at 7:38 PM, Holly Raiche <h.raiche at internode.on.net> wrote:

Folks

Maybe we need to back up a bit and go back to the Charter and what we are supposed to be doing. Let me quote directly from it:

First - background: Quoting the Charter on the Board decision to launch this PDP:

On 26 May, 2015, the ICANN Board passed a resolution adopting that Process Framework and reaffirming its 2012 request for a Board - initiated PDP to define the purpose of collecting, maintaining and providing access to gTLD registration data, and to consider safeguards for protecting data, using the recommendations in the EWG’s Final Report as an input to, and, if appropriate, as the foundation for a new gTLD policy

Later - what The Charter tasked this Working Group with:

As part of its Phase 1 deliberations, the PDP WG should work to reach consensus recommendations by considering, at a minimum, the following complex and inter-related questions:

 Users/Purposes: Who should have access to gTLD registration data and why?

 Gated Access: What steps should be taken to control data access for each user/purpose?

 Data Accuracy: What steps should be taken to improve data accuracy?

 Data Elements: What data should be collected, stored, and disclosed?

 Privacy: What steps are needed to protect data and privacy?

 Coexistence: What steps should be taken to enable next-generation RDS coexistence with and replacement of the legacy WHOIS system?

Compliance: What steps are needed to enforce these policies?

 System Model:What system requirements must be satisfied by any next-generation RDS implementation?

 Cost: What costs will be incurred and how must they be covered?

 Benefits: What benefits will be achieved and how will they be measured?

 Risks: What risks do stakeholders face and how will they be reconciled?

So accuracy’s there - along with a lot of other issues. That is not saying that accuracy is not covered in existing requirements on registries/registrars. But it is giving a broader meaning to RDS - i.e., it’s not just about collection, maintenance and access to data; it’s also about safeguards, etc - using the EWG work.

So thanks Rob. It’s a bit premature to rule issues out when they are well and truly on our table.

Holly

On 6 Oct 2016, at 6:37 am, Rod Rasmussen <rrasmussen at infoblox.com> wrote:

Folks,

Gotta chime in here, since the EWG provided a lot of thinking on this issue. If you haven’t already, please review the EWG report sections on data accuracy and also the concept of data validators and their relationship to the RDS. For example, I would note that a well-provisioned RDS would be able to provide some sort of validation checks against existing data in the use case of trying to prevent impersonation (a form of accuracy) of an existing registrant (a big brand like Facebook for instance). Another concept we found very important in the EWG is the idea of creating a contact data set tied to a contact ID that is portable between registrars and registries. This provides for the purpose-based contacts we talk about at great length in the report. It also is key for addressing some of the fundamental operational issues that lead to inaccurate, out-of-date data at various registrars. If you have a change in your contact information (a new e-mail for instance) and hold multiple roles in conjunction with many domains, you have a real challenge making updates throughout the universe of your domain names. Using a data validator and then acting via the RDS, when you make a change to your contact info, that automatically can be reflected in all domains you are associated with and thus improve accuracy tremendously. Those are just a couple examples of how an RDS can be involved in dealing with accuracy issues and represent many of the concepts you can address once you look beyond the current paradigm of registrar controlled contact information anchored specifically to individual domain names. Accuracy in the “generic” system (including registries, registrars, RDS, validators, some other group we haven’t thought of yet) is definitely in-scope. How that is done can take many forms and could have different roles played by different participants in the entire ecosystem.

Cheers,

Rod

On Oct 5, 2016, at 10:36 AM, [ benny at nordreg.se](mailto:benny at nordreg.se) wrote:

But the data accuracy can’t be done in RDS, the accuracy is done on a registrar level when collecting data.

RDS shall under no circumstances alter any information received from registry / registrars and showing any different info than what is collected on that level.

WG can look at what accuracy they want registrars to do yes, but RDS doesn’t do anything.

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Med vänliga hälsningar / Kind Regards / Med vennlig hilsen

Benny Samuelsen
Registry Manager - Domainexpert

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From: <gnso-rds-pdp-wg-bounces at icann.org> on behalf of "Metalitz, Steven" <met at msk.com>
Date: Wednesday, 5 October 2016 at 19:32
To: 'Marika Konings' <marika.konings at icann.org>, Volker Greimann <vgreimann at key-systems.net>, "gnso-rds-pdp-wg at icann.org" <gnso-rds-pdp-wg at icann.org>
Subject: Re: [gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose

Volker, what is the basis for your assertion that “data will be presented "as is" in this system, with no

presumption of any prior cleanup work”?

That statement will be true if we ultimately conclude that the current system is adequate and that we do not recommend establishment of a new RDS. However, if we do recommend a new system, then improvements to data accuracy are very much on the table, as the charter provision quoted by Marika indicates.

Steve Metalitz

From: gnso-rds-pdp-wg-bounces at icann.org [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of Marika Konings
Sent: Wednesday, October 05, 2016 12:53 PM
To: Volker Greimann; gnso-rds-pdp-wg at icann.org
Subject: Re: [gnso-rds-pdp-wg] For your review - updated RDS Statement of Purpose

Volker, please note that the PDP WG Charter (see https://community.icann.org/x/E4xlAw) includes the following question:

As part of its Phase 1 deliberations, the PDP WG should workto reach consensus recommendations by considering, at a minimum, the following complex and inter-related questions:

(…..)

·  Data Accuracy: What steps should be taken to improve data accuracy?

(……)

Best regards,

Marika

On 05/10/16 05:58, "[gnso-rds-pdp-wg-bounces at icann.org on behalf of Volker Greimann](mailto:gnso-rds-pdp-wg-bounces at icann.org%20on%20behalf%20of%20Volker%20Greimann)" <[gnso-rds-pdp-wg-bounces at icann.org on behalf of vgreimann at key-systems.net](mailto:gnso-rds-pdp-wg-bounces at icann.org%20on%20behalf%20of%20vgreimann at key-systems.net)> wrote:

I would move to strike all references to data quality altogether from

this document, e.g. "current", "accurate" etc.

These are already required by existing policies and agreements and do

not have to be referenced again at this point. We should focus on having

to reflect the data as provided by the RNH at this stage, not make any

presumptions about its quality.

After all, data will be presented "as is" in this system, with no

presumption of any prior cleanup work.

Best,

Volker

>> THE purpose of the "Registration Data Service" (hereafter referred to

>> as

>> "RDS") is to manage authorised parties' access to information about

>> [gTLD Domain Names, gTLD Nameservers, gTLD Registries and gTLD

>> Registrars]

>>

>> Purpose 3(a/b) are possible use cases, not Purposes as such

>>

>> "Accurate" is definitely not a term to use if we ever expect to finish

>> - "Current" would be more accurate (sic) / appropriate.

> Agreed, with one minor suggestion:

>

> "access to information about generic top-level domain registries, registrars, names, and name servers."

>

> Scott

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