[gnso-rds-pdp-wg] IMPORTANT: Notes from RDS PDP WG Meeting - 3 October

theo geurts gtheo at xs4all.nl
Fri Oct 6 13:59:30 UTC 2017


That definition is also used in other parts of the world, not just the 
GDPR.

And I agree, it is very clear.

The community has to be very precise about these purposes and view them 
through a data protection prism first.
This will allow the community to come up with technical solutions and 
policies for those purposes and solve 80% of the purposes mentioned in 
the purpose matrix published by ICANN without putting ICANN and it's 
community in the data controller seat.

The other 20% will require some real outside of the box 
thinking/solutions there.

Theo


On 6-10-2017 15:17, Chuck wrote:
>
> Thanks Jonathan.  This seems very helpful regarding the definitions of 
> personal data controllers and processors.
>
> The following seems pretty clear to me in the context of the ICANN 
> community it will be up to others to decide that.
>
> “/‘Controller’ shall mean the natural or legal person, public 
> authority, agency or/
>
> /any other body which alone or jointly with others determines the 
> purposes and/
>
> /means of the processing of personal data; where the purposes and 
> means of/
>
> /processing are determined by national or Community laws or 
> regulations the/
>
> /controller or the specific criteria for his nomination may be 
> designated by/
>
> /national or Community law;/
>
> /‘Processor’ shall mean a natural or legal person, public authority, 
> agency or any/
>
> /other body which processes personal data on behalf of the controller./”
>
> Chuck
>
> *From:* jonathan matkowsky [mailto:jonathan.matkowsky at riskiq.net]
> *Sent:* Thursday, October 05, 2017 7:52 PM
> *To:* Chuck <consult at cgomes.com>
> *Cc:* gnso-rds-pdp-wg at icann.org
> *Subject:* Re: [gnso-rds-pdp-wg] IMPORTANT: Notes from RDS PDP WG 
> Meeting - 3 October
>
> This may be of interest 
> http://ec.europa.eu/justice/policies/privacy/docs/wpdocs/2010/wp169_en.pdf
>
> On Wed, Oct 4, 2017 at 12:15 PM Chuck <consult at cgomes.com 
> <mailto:consult at cgomes.com>> wrote:
>
>     If any of you were on the ICANN GDPR webinar earlier today, you
>     know that I raised this issue and said that I thought it would be
>     helpful if ICANN Org accepted the fact that it is a controller for
>     at least some personal data.  That said though, I would be
>     surprised if it doesn’t take quite a bit of time to make a
>     decision on that, so my suggestion is that we don’t delay our work
>     while we wait on that. There is plenty of work of us to do
>     regardless of who the data controllers are.
>
>     Chuck
>
>     *From:* gnso-rds-pdp-wg-bounces at icann.org
>     <mailto:gnso-rds-pdp-wg-bounces at icann.org>
>     [mailto:gnso-rds-pdp-wg-bounces at icann.org
>     <mailto:gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of *Ayden
>     Férdeline
>     *Sent:* Wednesday, October 04, 2017 11:13 AM
>     *To:* jonathan matkowsky <jonathan.matkowsky at riskiq.net
>     <mailto:jonathan.matkowsky at riskiq.net>>
>     *Cc:* gnso-rds-pdp-wg at icann.org <mailto:gnso-rds-pdp-wg at icann.org>
>
>
>     *Subject:* Re: [gnso-rds-pdp-wg] IMPORTANT: Notes from RDS PDP WG
>     Meeting - 3 October
>
>     I agree with your assessment here, Jonathan, that ICANN is a data
>     controller.
>
>     Best wishes, Ayden
>
>         -------- Original Message --------
>
>         Subject: Re: [gnso-rds-pdp-wg] IMPORTANT: Notes from RDS PDP
>         WG Meeting - 3 October
>
>         Local Time: 4 October 2017 6:13 PM
>
>         UTC Time: 4 October 2017 17:13
>
>         From: jonathan.matkowsky at riskiq.net
>         <mailto:jonathan.matkowsky at riskiq.net>
>
>         To: Marika Konings <marika.konings at icann.org
>         <mailto:marika.konings at icann.org>>, 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>>, lisa at corecom.com
>         <mailto:lisa at corecom.com> <lisa at corecom.com
>         <mailto:lisa at corecom.com>>
>
>         I’ve given more thought to this and it it seems now obvious to
>         me that ICANN is in fact a data Controller since alone or
>         jointly with others, it is determining the purposes and means
>         of the processing of the personal data.
>
>         Jonathan Matkowsky
>
>         On Wed, Oct 4, 2017 at 9:54 AM jonathan matkowsky
>         <jonathan.matkowsky at riskiq.net
>         <mailto:jonathan.matkowsky at riskiq.net>> wrote:
>
>             Marika, there needs to be a “data flow” diagram with an
>             analysis of the data from the time it’s provided by the
>             registrant until it makes its way into the Whois, and the
>             role that each registrar plays as controller vs processor,
>             and ICANN as a co-controller versus processor. All the
>             different obligations under the GDPR flow from these
>             categories and they trigger different types of
>             obligations. And that is unfortunately missing.
>
>             On Tue, Oct 3, 2017 at 5:29 PM Marika Konings
>             <marika.konings at icann.org
>             <mailto:marika.konings at icann.org>> wrote:
>
>                 Jonathan, I am not sure what you are referring to with
>                 ‘an analysis of ICANN as a data controller versus
>                 processor vs. co-controller’. I am not aware that
>                 anyone in particular is working on such an analysis
>                 but I am happy to stand corrected. I do note that the
>                 WSGR memorandum addresses the issue of controller in a
>                 number of its responses such as those to question 1
>                 and question 17.
>
>                 As Chuck indicated on the call, if/when responses are
>                 received to the limited number of follow up questions,
>                 these will be shared with the WG.
>
>                 Best regards,
>
>                 Marika
>
>                 *From: *<gnso-rds-pdp-wg-bounces at icann.org
>                 <mailto:gnso-rds-pdp-wg-bounces at icann.org>> on behalf
>                 of jonathan matkowsky <jonathan.matkowsky at riskiq.net
>                 <mailto:jonathan.matkowsky at riskiq.net>>
>                 *Date: *Tuesday, October 3, 2017 at 15:04
>                 *To: *"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>>, Lisa Phifer
>                 <lisa at corecom.com <mailto:lisa at corecom.com>>
>                 *Subject: *Re: [gnso-rds-pdp-wg] IMPORTANT: Notes from
>                 RDS PDP WG Meeting - 3 October
>
>                 Hi Lisa,
>
>                 —When will we get an analysis of ICANN as a data
>                 controller versus processor vs co-controller? How can
>                 we draw conclusions from the memo without this info?
>
>                 —What are the follow-up questions already posed to the
>                 law firm?
>
>                 Thanks
>
>                 Jonathan
>
>                 On Tue, Oct 3, 2017 at 3:33 PM Lisa Phifer
>                 <lisa at corecom.com <mailto:lisa at corecom.com>> wrote:
>
>                     *Dear all,*
>
>                     *Below please find notes from today’s RDS PDP WG
>                     meeting.*
>
>                     *To recap Action Items from today’s call:*
>
>                     ·*Action Item:* Staff to incorporate WG agreement
>                     in working draft.
>
>                     ·*Action Item:* WG leadership team to consider
>                     input received during today's meeting and consider
>                     how to move forward as today's meeting did not
>                     achieve the goal of moving forward on these questions.
>
>                     *Best regards,*
>                     *Lisa*
>
>                     **
>
>                     _Action Items and Notes from RDS PDP WG Call – 3
>                     October 2017_
>
>                     /These high-level notes are designed to help PDP
>                     WG members navigate through the content of the
>                     call and are not meant as a substitute for the
>                     transcript and/or recording. The MP3, transcript,
>                     and chat are provided separately and are posted on
>                     the wiki here:
>                     /https://community.icann.org/x/bWfwAw[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_x_bWfwAw&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=4KHESqzP9NmlfumEghxako3KC7O-WGxT-TXjxYSCgXc&e=>
>
>                     1. Roll Call/SOI Updates
>
>                     ·No SOI updates identified
>
>                     2. Apply results from last week’s poll to working
>                     document
>
>                     ·https://community.icann.org/download/attachments/66086765/AnnotatedResults-Poll-from-26SeptCall.pdf[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_AnnotatedResults-2DPoll-2Dfrom-2D26SeptCall.pdf&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=GxZzR0dVr7ytyC8X_yDY1AyGTyVYRZ3Ecgbez36rWxA&e=>
>
>                     ·22 members participated in poll
>
>                     ·77% still don't think Original Registration Date
>                     should be a new data element
>
>                     ·Record in working document as tentative agreement
>
>                     *WG Agreement: *There is no requirement for the
>                     Original Registration Date as proposed by the EWG
>                     Final Report
>
>                     *Action Item:* Staff to incorporate WG agreement
>                     in working draft.
>
>                     3. General questions about WSGR memo
>
>                     ·https://gnso.icann.org/en/drafts/wsgr-icann-memorandum-25sep17-en.pdf[gnso.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__gnso.icann.org_en_drafts_wsgr-2Dicann-2Dmemorandum-2D25sep17-2Den.pdf&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=2doxZn4IxSgdwjUDmWxeg3UdGggQLYV-QKzqnRTNw_8&e=>
>
>                     ·Leadership in consultation with legal advisors
>                     within WG have been working to extract principles
>                     from WSGR memo and also answers previously
>                     supplied by senior EU privacy experts, to be
>                     applied to our work going forward
>
>                     ·How was the law firm selected? Several candidates
>                     with expertise identified by staff and augmented
>                     with suggestions from legal advisors within WG.
>                     Using that input, candidates were evaluated and
>                     chosen based on experience, reputation, etc.
>                     Selection was ultimately made by leadership team
>                     not advisory group, with group's input on two
>                     finalists.
>
>                     ·Do we intend to go back to the law firm to ask
>                     for more typical legal advice - that is, tell them
>                     what we propose doing, and ask for advice on legal
>                     risks associated with proposal? Yes, we can seek
>                     legal advice in the future, from this firm or
>                     another firm, at appropriate points in our work -
>                     that will incur additional cost to seek answers to
>                     new questions.
>
>                     ·Were discussions with law firm recorded, or can a
>                     transcript be provided? The leadership team and
>                     legal advisors reviewed a confidential draft for
>                     the purpose of identifying any items required
>                     clarification, enabling finalization of the memo.
>
>                     ·The law firm explicitly asked that draft not be
>                     shared and be treated as confidential; they prefer
>                     to share only final work product. In some cases,
>                     they asked for clarification of the questions that
>                     were asked by WG. We can share questions that were
>                     asked, but those questions focused on
>                     clarification and not questioning views or
>                     opinions expressed by WSGR.
>
>                     ·How much did the advisory team feedback impact
>                     the ultimate questions? Not at all. The questions
>                     were developed by the WG prior to ICANN58 meeting,
>                     and then presented to full WG for
>                     review/edit/approval. Those questions were then
>                     published and asked of senior EU privacy experts
>                     in CPH. We intentionally gave WSGR the same
>                     questions (exactly) as were given to experts at CPH.
>
>                     ·Now it's time to take inputs received from two
>                     sources and use it to address work outlined in our
>                     charter...
>
>                     4. Introduce methodology to be used to apply memo
>                     to our work
>
>                     ·Charter questions: Users/Purposes, Gated Access,
>                     Data Accuracy, Data Elements, and Privacy -
>                     fundamental questions to be addressed in Phase 1
>
>                     ·We have already examined all but Accuracy to some
>                     degree, mostly for MPDS
>
>                     ·What we're going to do today is to start with
>                     Charter question on Privacy and look at how inputs
>                     from senior EU privacy experts AND WSGR help us
>                     answer or move forward in addressing that
>                     question/sub-questions
>
>                     5. Starting with charter question on Privacy for
>                     deliberation
>
>                     a. Introduce DP/Privacy principles related to the
>                     charter question on Privacy
>
>                     ·https://community.icann.org/download/attachments/66086765/Handout-RDS-WG-Call-3Oct2017.pdf[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_Handout-2DRDS-2DWG-2DCall-2D3Oct2017.pdf&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=gcPnRmTPeTHit2L-lYOL1zSYozVfG_wYMSWTdoBb40c&e=>
>
>                     ·Copied extracted principles in handout, mapped to
>                     the charter question on privacy and associated
>                     sub-questions, to facilitate reference during
>                     deliberation on those questions
>
>                     ·Note that at end of handout there appears the one
>                     WG agreement thus far under the Privacy charter
>                     question, which was limited to MPDS: 14. [For
>                     MPDS] Existing gTLD RDS policies do NOT
>                     sufficiently address compliance with applicable
>                     data protection, privacy, and free speech laws
>                     about purpose
>
>                     ·Review of principles mapped to this charter
>                     question/sub question:
>
>                     ·/5.1 Do existing gTLD registration directory
>                     services policies sufficiently address compliance
>                     with applicable data protection, privacy, and free
>                     speech laws within each jurisdiction?/
>
>                     b. Starting with Privacy sub-question 5.1, discuss
>                     impact on WG agreements
>
>                     ·We are not restricted to EU focus of this input;
>                     the input does provide guidance with respect to
>                     that jurisdiction. Our task is to provide
>                     requirements for RDS that takes into consideration
>                     all jurisdictions.
>
>                     ·“Within each jurisdiction” = within ALL
>                     jurisdictions of the world
>
>                     ·Re: 3.e. The GDPR applies to all personal data,
>                     comments that GDPR does NOT apply to all personal data
>
>                     ·Answer could be "yes" if taking into account
>                     procedure for dealing with conflicts with local law
>
>                     ·Conflating two different issues: policy and
>                     implementation. Reading RAA it matches up with
>                     GDPR, but the way it's been implemented does not
>                     (e.g., purpose, consent). Need to ask whether
>                     policies address compliance or whether
>                     implementation of those policies do or do not
>
>                     ·Comment: The policy as it is written is tightly
>                     bound to the extreme limitations of
>                     whois-the-protocol, which is part of the problem
>
>                     ·For example, from RAA: /3.7.7.4 Registrar shall
>                     provide notice to each new or renewed Registered
>                     Name Holder stating:3.7.7.4.1 The purposes for
>                     which any Personal Data collected from the
>                     applicant are intended;3.7.7.4.2 The intended
>                     recipients or categories of recipients of the data
>                     (including the Registry Operator and others who
>                     will receive the data from Registry
>                     Operator);3.7.7.4.3 Which data are obligatory and
>                     which data, if any, are voluntary; and 3.7.7.4.4
>                     How the Registered Name Holder or data subject can
>                     access and, if necessary, rectify the data held
>                     about them.3.7.7.5 The Registered Name Holder
>                     shall consent to the data processing referred to
>                     in Subsection 3.7.7.4./
>
>                     ·Is data escrow within the RDS's scope?
>
>                     ·Do questions not line up with existing policy,
>                     producing answers that are not useful? This is why
>                     people are concerned about questions - if you ask
>                     the wrong question, you don't get helpful answers
>
>                     ·Maybe the question should be "Do the existing
>                     implementations of gTLD policy sufficient address
>                     compliance....?
>
>                     ·Comment: Current policies violate GDPR for EU
>                     citizens - example CL&D
>
>                     ·Need to distinguish policies from implementation,
>                     which is informed by decisions about who the data
>                     controller is
>
>                     ·Note that WSGR did not respond to the questions
>                     that are in this document - these are questions
>                     that the WG identified as sub-questions to help
>                     address the overarching charter questions. The
>                     principles that you see were derived from the memo
>                     as aiming to assist in responding to these questions.
>
>                     ·Possible reframing of sub-question 5.1: /Do
>                     existing gTLD registration directory services
>                     policies and/or implementations PREVENT compliance
>                     with applicable data protection, privacy, and free
>                     speech laws within each jurisdiction?/
>
>                     ·Would re-applying existing policy, using RDAP
>                     instead of WHOIS, shed any light on whether it's
>                     the policy or the implementation that prevent
>                     compliance with applicable laws?
>
>                     *Action Item:* WG leadership team to consider
>                     input received during today's meeting and consider
>                     how to move forward as today's meeting did not
>                     achieve the goal of moving forward on these questions.
>
>                     6. Confirm action items and proposed decision points
>
>                     ·*WG Agreement: *There is no requirement for the
>                     Original Registration Date as proposed by the EWG
>                     Final Report
>
>                     ·*Action Item:* Staff to incorporate WG agreement
>                     in working draft.
>
>                     ·*Action Item:* WG leadership team to consider
>                     input received during today's meeting and consider
>                     how to move forward as today's meeting did not
>                     achieve the goal of moving forward on these questions.
>
>                      7. Confirm next WG meeting (Tuesday 10 October at
>                     16.00 UTC)
>
>                     _Meeting Materials (all posted at
>                     https://community.icann.org/x/bWfwAw[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_x_bWfwAw&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=4KHESqzP9NmlfumEghxako3KC7O-WGxT-TXjxYSCgXc&e=>)_
>
>
>                     ·*26 September Call poll (closed COB Saturday 30
>                     September)*
>
>                     ·*Link to participate*:
>                     https://www.surveymonkey.com/r/JM679DR[surveymonkey.com]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.surveymonkey.com_r_JM679DR&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=80KHlbgsAUZ12B7MkyZpaxsYR1VNcDnNXeGyZU5JlII&e=>
>
>                     ·*PDF of Poll Questions*:
>                     Poll-from-26SeptemberCall.pdf[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086762_Poll-2Dfrom-2D26SeptemberCall.pdf-3Fversion-3D1-26modificationDate-3D1506462198000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=Qh0wpwEJhnmMtn0WjUrDH--J5pDrK3j-XSvG9SkCoBE&e=>
>
>                     ·*SurveyMonkey Summary Poll Results:
>                     *SummaryResults-Poll-from-26SeptCall.pdf[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_SummaryResults-2DPoll-2Dfrom-2D26SeptCall.pdf-3Fversion-3D1-26modificationDate-3D1506882150000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=YthnS4kRZFpcDW3V2wu5_4o2iacXHMPOm9-8pCh15Ts&e=>
>
>                     ·*SurveyMonkey Raw Data Poll Results:
>                     *RawDataResults-Poll-from-26SeptCall.zip[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_RawDataResults-2DPoll-2Dfrom-2D26SeptCall.zip-3Fversion-3D1-26modificationDate-3D1506882171000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=GD_nKg2UD1C_5fk9Nu-8iWjbqBznGdRjovHat2Vsiz8&e=> and
>                     XLS[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_RawDataResults-2DPoll-2Dfrom-2D26SeptCall.xlsx-3Fversion-3D1-26modificationDate-3D1506882190000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=sgYSSm5kVL1ORiWVra_xH_U_W8Szr60a2ofA5cMhAFA&e=>
>
>                     ·*Annotated Survey Results:
>                     *AnnotatedResults-Poll-from-26SeptCall.pdf[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_AnnotatedResults-2DPoll-2Dfrom-2D26SeptCall.pdf-3Fversion-3D1-26modificationDate-3D1506963736000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=9PuB-N3Zz2zIaw8bKfiyR-TppIjiMhl7BO57I1_yQt8&e=>
>
>                     ·WSGR memorandum:
>                     https://gnso.icann.org/en/drafts/wsgr-icann-memorandum-25sep17-en.pdf[gnso.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__gnso.icann.org_en_drafts_wsgr-2Dicann-2Dmemorandum-2D25sep17-2Den.pdf&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=2doxZn4IxSgdwjUDmWxeg3UdGggQLYV-QKzqnRTNw_8&e=>
>
>                     ·Principles from DP Expert and WSGR - 29 Sept
>                     2017.docx[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_Principles-2520from-2520DP-2520Expert-2520and-2520WSGR-2520-2D-252029-2520Sept-25202017.docx-3Fversion-3D1-26modificationDate-3D1506964656000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=kmC6D7EdNgHgKZ9sUHlKD98-MbEeT1aDl_0l40vc74w&e=>
>
>                     ·Handout-RDS-WG-Call-3Oct2017.pdf[community.icann.org]
>                     <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_66086765_Handout-2DRDS-2DWG-2DCall-2D3Oct2017.pdf-3Fversion-3D1-26modificationDate-3D1506979314000-26api-3Dv2&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=pSoLE7Y91MVjMmhJ-xbOcyqU8WJlZg4XQXqvhIgGu_0&s=OmxAWn8um4-fiyFlpuMK8T1wlIQ1bz-1gXS4eIsBnRY&e=>
>
>                     _______________________________________________
>
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>                 Jonathan Matkowsky
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