[gnso-rds-pdp-wg] Legal basis vs. lawful
John Horton
john.horton at legitscript.com
Tue Feb 13 19:07:14 UTC 2018
Well, the other thing there would be whether (picking random countries here
to use an example) if I'm a US citizen and resident (which I in fact am),
can I avail myself of Panamanian privacy laws by choosing a privacy/proxy
service that displays a Panama address? I'd presume we'd all agree that's
not the intent. (My assumption is that eNom's privacy service is a separate
corporation registered in Panama, but again, that's a guess.)
John Horton
President and CEO, LegitScript
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On Tue, Feb 13, 2018 at 11:02 AM, Stephanie Perrin <
stephanie.perrin at mail.utoronto.ca> wrote:
> INteresting. And it does appear they have some data protection provisions
> in their E-Commerce bill, updated in 2016, but the summary I read sounded
> more like data retention requirements that data protection, so I would not
> count them until proven otherwise.
>
> cheer Stephanie
> On 2018-02-13 13:49, John Horton wrote:
>
> Re: Panama -- my guess is eNom's privacy/proxy service? I don't think it's
> actually registrants based in Panama -- my guess is that the data just
> cited probably only accounts for the country in the Whois field (so if it's
> p/p it's not necessarily identifying the registrant's actual country --
> would be interesting to exclude p/p Whois records to see what the data
> show). In the same vein, DomainsByProxy is generally (always?) US, I think,
> but I'd assume that there are registrants in other countries using DBP.
> Just a guess.
>
> John Horton
> President and CEO, LegitScript
>
>
> *Follow LegitScript*: LinkedIn
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>
>
>
>
> On Tue, Feb 13, 2018 at 10:46 AM, Stephanie Perrin <stephanie.perrin at mail.
> utoronto.ca> wrote:
>
>> Japan and Canada have legislation, add another 7.7, I am looking up
>> Panama to check. I am confident that in the block of other countries
>> (24.6) there will be quite a few with DP law. (PS why on earth does Panama
>> have such a large registration? retired Americans? Favorable liability
>> laws?)
>>
>> Stephanie
>>
>>
>> On 2018-02-13 13:36, Volker Greimann wrote:
>>
>> That brings us back to the question whether we would want a unified DNS
>> system or a fractured one. I personally think 14% of the worlds
>> registrations are quite a significant number, but even if you do not, does
>> this mean you would prefer fragmentation of policies and rules?
>>
>> Am 13.02.2018 um 19:18 schrieb John Horton via gnso-rds-pdp-wg:
>>
>> +1 (to Greg)
>>
>> On Tue, Feb 13, 2018 at 10:09 AM Greg Aaron <gca at icginc.com> wrote:
>>
>>> What are the jurisdictions where gTLD registrants are located? The
>>> stats indicate that a distinct minority of gTLD registrations and
>>> registrants may qualify for GDPR protection. According to ICANN’s metrics,
>>> 14% of registrants are in the EU. The top jurisdictions are:
>>>
>>>
>>>
>>> USA 41.0%
>>>
>>> EU countries 14.0%
>>>
>>> China 9.4%
>>>
>>> Canada 4.2%
>>>
>>> Japan 3.5%
>>>
>>> Panama 3.3%
>>>
>>> [other 24.6%]
>>>
>>>
>>>
>>> These stats don’t tell us exactly how many registrations might involve
>>> GDPR (affecting that are the jurisdictions of the various parties involved
>>> in any given registartion, the fact that legal person in the EU are not due
>>> the same protection as natural persons, etc.). Still, that 14% is
>>> interesting.
>>>
>>>
>>>
>>> The European Commission itself recently told ICANN that solutions can
>>> and should be balanced, to “preserve the proper use of WHOIS while ensuring
>>> full compliance with the (current and future) EU data protection rules”,
>>> and that GDPR only applies to the personal data of natural persons in the
>>> EU.
>>>
>>>
>>>
>>> So, what justifies extending a particular protection regime (baseline)
>>> to all registrants worldwide, especially when a technical system can
>>> support situational-based needs? Over-compliance is not necessary, and
>>> over-compliance erodes the proper use of WHOIS. I suggest that a proper
>>> solution is to enable compliance with a rule in the situations in which the
>>> rule applies. The proper solution is not to over-apply a rule, or to apply
>>> the rule where it does not have power.
>>>
>>>
>>>
>>> All best,
>>>
>>> --Greg
>>>
>>>
>>>
>>> Source: https://www.icann.org/resources/pages/cct-metrics-domain-
>>> name-registration-2016-06-27-en
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> **********************************
>>>
>>> Greg Aaron
>>>
>>> Vice-President, Product Management
>>>
>>> iThreat Cyber Group / Cybertoolbelt.com
>>>
>>> mobile: +1.215.858.2257 <(215)%20858-2257>
>>>
>>> **********************************
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>>>
>>>
>>> *From:* gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org] *On
>>> Behalf Of *Kathy Kleiman
>>> *Sent:* Tuesday, February 13, 2018 11:24 AM
>>>
>>>
>>> *To:* gnso-rds-pdp-wg at icann.org
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> More than half the countries in the world now have comprehensive data
>>> protection laws, and the number grows every year. We found that in our
>>> research of foundation documents at the start of this WG. The tipping point
>>> took place in 2015. As it happens, Volker's approach simply does take this
>>> perspective into account.
>>>
>>> Best, Kathy
>>>
>>> On 2/13/2018 11:04 AM, Dotzero wrote:
>>>
>>> Volker, you assert that "it would be sensible to take GDPR as a basis
>>> and start from there". Perhaps sensible from your perspective and easier
>>> from your perspective but ICANN is an international organization -
>>> primarily dealing with technical/administrative issues - and it MUST take
>>> an approach that, as best it can, accommodates the laws and practices of
>>> various jurisdictions around the world. Your proposed approach, quite
>>> simply does not do that.
>>>
>>> Michael Hammer
>>>
>>> On Tue, Feb 13, 2018 at 10:54 AM, Volker Greimann <
>>> vgreimann at key-systems.net> wrote:
>>>
>>> I think that it would be sensible to take the GDPR as a basis and start
>>> from there. Obviously, where it conflicts with other applicable laws, we
>>> should make sure to accomodate those as well, but as the EU Commission and
>>> others have pointed out is that compliance with GDPR does not preclude
>>> providing certain access levels to certain parties. What those levels would
>>> be and who those parties could be should be the main focus of our work.
>>>
>>>
>>>
>>> Am 13.02.2018 um 15:41 schrieb Chuck:
>>>
>>> Volker,
>>>
>>>
>>>
>>> Are you saying that you think that RDS policies should be designed to
>>> comply with European regulations and then applied to all other
>>> jurisdictions in the world?
>>>
>>>
>>>
>>> Chuck
>>>
>>>
>>>
>>> *From:* Volker Greimann [mailto:vgreimann at key-systems.net
>>> <vgreimann at key-systems.net>]
>>> *Sent:* Tuesday, February 13, 2018 5:58 AM
>>> *To:* Chuck <consult at cgomes.com> <consult at cgomes.com>; 'Michael Palage'
>>> <michael at palage.com> <michael at palage.com>
>>> *Cc:* gnso-rds-pdp-wg at icann.org
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> I am afraid that if we create different policies for different regions,
>>> we will break the model, encourage forum shopping and encourage firewalling
>>> of entire geographic sections of the net. I hope that is not what we are
>>> doing here.
>>>
>>> GDPR will cause some breakage of this and I see it as our mission to fix
>>> this breakage of the standard by proposing a unified model once again.
>>>
>>> Ultimately, if this solution does what the EU has been asking for, e.g.
>>> protect legitimate use cases of registration data as well as the rights of
>>> the data subjects, there is no reason why it should not be universally
>>> applicable.
>>>
>>> Best,
>>>
>>> Volker
>>>
>>>
>>>
>>> Am 13.02.2018 um 00:04 schrieb Chuck:
>>>
>>> Volker,
>>>
>>>
>>>
>>> The WG could recommend policies that are ‘universally applicable to all
>>> registrations’ but I seriously doubt that will happen in today’s world.
>>> That would be much simpler than policies that vary by region and users, but
>>> is it realistic?
>>>
>>>
>>>
>>> Chuck
>>>
>>>
>>>
>>> *From:* gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>> <gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of *Volker Greimann
>>> *Sent:* Monday, February 12, 2018 2:30 PM
>>> *To:* Michael Palage <michael at palage.com> <michael at palage.com>
>>> *Cc:* gnso-rds-pdp-wg at icann.org
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> Michael is right. ICANN iOS based on the thought of “One World; one
>>> Internet”. This also means that the policies it creates should be
>>> universally applicable to all registrations, if possible. IF we start
>>> creating policy that diverges, that would only lead to further
>>> fragmentation and undermine the founding ideal of ICANN itself. Our aim
>>> should be to create one policy that can be applied to all or most
>>> registrations and that can be implemented by all registrars alike.
>>>
>>>
>>>
>>> While we will likely have a certain amount of fragmentation following
>>> May 25 as each contracted party applies its own solution, it should be our
>>> goal to overcome this and present a new unified policy that works for all
>>> contracted parties.
>>>
>>>
>>>
>>> Volker
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> On 12. Feb 2018, at 20:27, Michael Palage <michael at palage.com> wrote:
>>>
>>>
>>>
>>> Greg/John,
>>>
>>>
>>>
>>> I will respectfully push back on your legal over simplification of the
>>> GDPR.
>>>
>>>
>>>
>>> The exterritorial aspect of the GDPR set forth in Article 3 is NOT just
>>> limited to EU residents/citizens. As Michele has noted in the past, the
>>> GDPR requires BlackKnight as an Irish legal entity to protect all of its
>>> customers data (EU/Non-EU) in compliance with GDPR, as well as US entities
>>> that target and conduct business within the EU.
>>>
>>>
>>>
>>> Now your points about the distinction between natural and legal persons
>>> is a fair one and one that has been noted in EU and Art 29 communications.
>>> Could you please share the basis of your proposition that 97% of all domain
>>> name registrations are registered by legal entities.
>>>
>>>
>>>
>>> As I have note previously the long term viability of the ICANN
>>> multi-stakeholder model is at risk as national governments continue to pass
>>> national laws that impact the operation of the Internet. However, the
>>> European Union is NOT alone in advancing Privacy Legislation, in fact data
>>> localization is perhaps the next biggest lurking threat to the domain name
>>> system.
>>>
>>>
>>>
>>> Best regards,
>>>
>>>
>>>
>>> Michael
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> *From:* gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>> <gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of *John Horton via
>>> gnso-rds-pdp-wg
>>> *Sent:* Monday, February 12, 2018 1:22 PM
>>> *To:* Greg Aaron <gca at icginc.com>
>>> *Cc:* gnso-rds-pdp-wg at icann.org
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> I think Greg is right on. There's simply no justification to force a law
>>> that is only intended to apply to a) EU residents/citizens that are b)
>>> natural persons not using the domain name for commercial purposes, to the
>>> remaining...what? 97% - 99% of the world's registrant population? That
>>> would be a balanced way to implement all of this.
>>>
>>> John Horton
>>> President and CEO, LegitScript
>>>
>>> [image:
>>> https://docs.google.com/uc?export=download&id=0B13GfLt8zwZJRXE5UTAtclVxdTg&revid=0B13GfLt8zwZJSG9zOUVwN1lFKzFrRVlnaWU0NGZ4RmdkUjg4PQ]
>>>
>>>
>>>
>>> *Follow* *Legit**Script*: LinkedIn
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>>> [image:
>>> https://www.legitscript.com/wp-content/uploads/2015/09/LegitScript-Workplace.png][image:
>>> https://docs.google.com/uc?export=download&id=0B13GfLt8zwZJTmNWbmcwOTVJMXc&revid=0B13GfLt8zwZJQlZWOXVGbG9acC9nRGhzdEkxclFJVytCWVNjPQ]
>>>
>>>
>>>
>>> On Mon, Feb 12, 2018 at 9:57 AM, Greg Aaron <gca at icginc.com> wrote:
>>>
>>> I don’t know if we arrive at the same place.
>>>
>>>
>>>
>>> GDPR is based on one principle. It states what is legal. It's explicit
>>> about what you _are allowed to do_; granted there’s some flexibility and
>>> room for interpretation. It’s like saying what’s inside a box.
>>>
>>>
>>>
>>> U.S. law is one based on different principles. AFAIK U.S. consumer
>>> protection law does not enumerate specifically what is lawful. Instead it
>>> tends to state what is illegal, what you are _not allowed to do_. It’s
>>> like saying what’s outside the box. The U.S. doesn’t have something like
>>> GDPR that spells out legal bases for collecting data, i.e. the enumerated
>>> allowable reasons. Instead the trade and consumer protection laws
>>> basically say: entities have the right to form contracts between
>>> themselves, they should live up to the contract, don’t surprise people,
>>> don’t do certain dishonest things.
>>>
>>>
>>>
>>> Here's the problem: if one makes the GDPR principle the ICANN standard
>>> and you apply it to all registrations, then practices that are allowable in
>>> one place under the law (like the U.S.) would no longer be allowed there by
>>> ICANN policy. ICANN would be choosing one legal approach or regime for
>>> everyone in the world.
>>>
>>>
>>>
>>> The alternative is to apply the GDRP only to those that it is designed
>>> to protect: registrants in the EU.
>>>
>>>
>>>
>>> For example, there’s nothing in U.S. law that prohibits a U.S. registrar
>>> from having a contract that says publication of full contact data in WHOIS
>>> is a condition of registering a domain name if you are a registrant in the
>>> U.S.
>>>
>>>
>>>
>>> See https://iapp.org/news/a/explaining-the-gdpr-to-an-american/ for
>>> more.
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>> *From:* gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>> <gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of *Silver, Bradley via
>>> gnso-rds-pdp-wg
>>> *Sent:* Friday, February 9, 2018 2:54 PM
>>> *To:* Volker Greimann <vgreimann at key-systems.net>; g
>>> nso-rds-pdp-wg at icann.org
>>>
>>>
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> It is true that the GDPR is prescriptive, although also rather
>>> open-ended (hence our current pickle). But regardless of the term we use,
>>> don’t we arrive at the same place: which is that if something that
>>> requires a legal basis is done without one, it will be unlawful? Using
>>> Kathy’s example, if data is processed without complying with minimization
>>> or purpose principles, will such processing not run afoul of the law, and
>>> hence be unlawful?
>>>
>>>
>>>
>>> There are important distinctions between the meaning of “legal basis”
>>> which implies that a law requires something to be affirmatively present,
>>> versus “lawful”, which means that something is not prohibited by law.
>>> Ultimately though, isn’t “lawfulness”, the same end point, regardless?
>>>
>>>
>>>
>>> *From:* gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>> <gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of *Volker Greimann
>>> *Sent:* Friday, February 09, 2018 11:27 AM
>>> *To:* gnso-rds-pdp-wg at icann.org
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> I do not see how. Kathy's analysis seems sound. The flexibility within
>>> the GDPR still only allows processing in very specific cicumstances, all of
>>> which are listed in the GDPR.
>>>
>>>
>>>
>>> Am 09.02.2018 um 16:45 schrieb Victoria Sheckler:
>>>
>>> Kathy’s analysis breaks down on a practical level when one looks at the
>>> GDPR and what it says about when data can be processed. The GDPR allows
>>> for flexibility for what can be processed and when, and kathy’s analysis
>>> overlooks that point.
>>>
>>>
>>>
>>> *From:* gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org
>>> <gnso-rds-pdp-wg-bounces at icann.org>] *On Behalf Of *Kathy Kleiman
>>> *Sent:* Thursday, February 8, 2018 7:07 PM
>>> *To:* gnso-rds-pdp-wg at icann.org
>>> *Subject:* Re: [gnso-rds-pdp-wg] Legal basis vs. lawful
>>>
>>>
>>>
>>> Tx for the invitation to join, Chuck, and following up on the discussion
>>> of Sam and Tapani, let me add that criteria for processing must be clearer
>>> than something broadly within ICANN's mission statement and something
>>> permissible somewhere. The requirements under law are express and concrete.
>>>
>>>
>>> Specifically, GDPR Article 5(1)(b and c) states:
>>>
>>>
>>> *Personal data shall be: 2. "collected for specified, explicit and
>>> legitimate purposes and not further processed in a manner that is
>>> incompatible with those purposes"* (the "purpose limitation") AND
>>> * 3. "adequate, relevant and limited to what is necessary in relation
>>> to the purposes for which they are processed"* (the "data minimisation"
>>> requirement). [underline added]
>>>
>>> Thus, our first criteria of "consistent with ICANN's mission," is only
>>> the first step and we need to go further than even the 3 criteria we are
>>> discussing..
>>>
>>> Second, lawful and legal enter us into a debate over words and I have to
>>> agree with Sam and Tapani's analysis and let me add some of my own.
>>>
>>> "Legal" is the term we use for actions expressly allowed under law. How
>>> we process personal data under the GDRP falls into this category -- of
>>> processing expressly allowed under law. Whereas the term lawful is used for
>>> a much broader category of actions which are generally permissible and
>>> allowable.
>>>
>>> The term "legal" is much more consistent with our criteria statement
>>> because the processing of personal data by ICANN must clearly have a *valid
>>> legal basis* as expressly defined by data protection laws.
>>>
>>> Best regards,
>>> Kathy
>>>
>>> On 2/7/2018 10:53 AM, Sam Lanfranco wrote:
>>>
>>> Thanks Tapani,
>>>
>>> I will extract from your longer message.
>>> I deliberately kept my brief and less technical.
>>> I think we are in agreement here and I support your position.
>>>
>>> On 2/7/2018 1:07 AM, Tapani Tarvainen wrote:
>>>
>>> The key distinction, as I understand it, is that "lawful" would be
>>> defined by the negative, everything that some law does not prohibit,
>>>
>>> where as "legal basis" is defined by the positive, only things whose
>>> justification can be explicitly derived from law.
>>>
>>> <......>
>>>
>>> So I would prefer "legal basis" specifically in this sense: that any
>>> processing
>>> would have to be explicitly based on one of the criteria, or bases, as
>>> listed
>>> in GDPR Article 6, or similar explicit justification in other data
>>> protection legislation.
>>>
>>>
>>>
>>>
>>> _______________________________________________
>>>
>>> gnso-rds-pdp-wg mailing list
>>>
>>> gnso-rds-pdp-wg at icann.org
>>>
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>>
>> --
>> John Horton
>> President and CEO, LegitScript
>>
>>
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>> _______________________________________________
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