[gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is backwards

Paul Keating Paul at law.es
Thu Feb 15 16:24:32 UTC 2018 

Seriously, more personal data is collected by smart TVs and your mobile
phone!!

Lets get back on topic please.

From:  Volker Greimann <vgreimann at key-systems.net>
Date:  Thursday, February 15, 2018 at 4:56 PM
To:  Paul Keating <paul at law.es>, Chuck <consult at cgomes.com>,
<gnso-rds-pdp-wg at icann.org>
Subject:  Re: [gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is
backwards

>     
>  
> 
> I imagine you would. Anyone who needs big data for their job does. And that is
> not necessarily a bad thing as big data can be used for wonderful things.
>  
>  
> 
> Unless it conflicts with the personal rights of those you are collecting data
> on. Because they also do not like their data being available for anyone to
> see, forever.
>  
>  
> 
> Volker
>  
>  
>  
> Am 15.02.2018 um 16:47 schrieb Paul Keating:
>  
>  
>>  
>> Paraphrasing a person I know.
>>  
>> 
>>  
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>> The more data input the better as long as it is carefully considered.
>>  
>> 
>>  
>>  
>> I do NOT like the idea of relying on ICANN to receive input provided via
>> their interacting with a third party.  I would prefer to obtain the
>> unfiltered data.
>>  
>> 
>>  
>>  
>> Paul
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>> 
>>  
>>   
>> From:  Chuck <consult at cgomes.com> on behalf of Chuck <consult at cgomes.com>
>>  Date:  Thursday, February 15, 2018 at 3:56 PM
>>  To:  Paul Keating <paul at law.es>, 'Volker Greimann'
>> <vgreimann at key-systems.net>, <gnso-rds-pdp-wg at icann.org>
>>  Subject:  RE: [gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is
>> backwards
>>  
>>  
>> 
>>  
>>  
>>>  
>>>     
>>>  
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>>> 
>>> Apparently, ICANN org has been interacting with DPAs regarding a possible
>>> interim solution, so maybe we will get some helpful input from those
>>> efforts.  Note Stephanie¹s suggestion that we could submit questions to the
>>> DP experts that participated in our public meeting last year.
>>>  
>>>  
>>>  
>>> Chuck
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>>>  
>>>  
>>>  
>>>  
>>> 
>>> From: Paul Keating [mailto:Paul at law.es]
>>>  Sent: Thursday, February 15, 2018 6:10 AM
>>>  To: Chuck <consult at cgomes.com>; 'Volker Greimann'
>>> <vgreimann at key-systems.net>; gnso-rds-pdp-wg at icann.org
>>>  Subject: Re: [gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is
>>> backwards
>>>  
>>>  
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>>> 
>>> Chuck,
>>>  
>>>  
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>>> 
>>>  
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>>> 
>>> That said I really do like the idea of having interaction and participation
>>> by the DPAs and even someone from Article 29 or other GDPR official groups.
>>> Otherwise we continue to work in a vacuum.
>>>  
>>>  
>>>  
>>> 
>>>  
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>>>  
>>>  
>>> 
>>> From: gnso-rds-pdp-wg <gnso-rds-pdp-wg-bounces at icann.org> on behalf of Chuck
>>> <consult at cgomes.com>
>>>  Date: Thursday, February 15, 2018 at 2:57 PM
>>>  To: 'Volker Greimann' <vgreimann at key-systems.net>,
>>> <gnso-rds-pdp-wg at icann.org>
>>>  Subject: Re: [gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is
>>> backwards
>>>  
>>>  
>>>  
>>> 
>>>  
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>>>  
>>>>  
>>>>  
>>>>  
>>>> 
>>>> I¹d like to think that the ICANN community effort going on outside this WG
>>>> will take note of the cybersecurity concerns that Allison raises as they
>>>> try to finalize an interim solution to deal with the GDPR in the near term.
>>>> Note this quote from Goren¹s latest blog that ICANN org is trying to find a
>>>> balanced approach:  ³This single, common interim model that is informed by
>>>> input from across the ICANN community would seek to obtain compliance with
>>>> both the GDPR and ICANN's contractual requirements related to registration
>>>> directory services.²  Here¹s the blog:
>>>> https://www.icann.org/news/blog/data-protection-privacy-update-latest-devel
>>>> opments 
>>>>  
>>>>  
>>>>  
>>>> Chuck
>>>>  
>>>>  
>>>>  
>>>>  
>>>>  
>>>> 
>>>> From: gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf
>>>> Of Volker Greimann
>>>>  Sent: Thursday, February 15, 2018 1:02 AM
>>>>  To: gnso-rds-pdp-wg at icann.org
>>>>  Subject: Re: [gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is
>>>> backwards
>>>>  
>>>>  
>>>>  
>>>>  
>>>>  
>>>> DPAs are law enforcement and will enforce the law of the land. They do not
>>>> have the option to pick and choose after May 25.
>>>>  
>>>> 
>>>> Maybe it is time for you and your colleagues to start looking at other
>>>> sources of information to ensure you can continue operation efficiently
>>>> once your currently chosen method becomes illegal. Remember, you are a data
>>>> processor too and what you do with that data could very well paint a target
>>>> on your backs that DPS may have to deal with.
>>>>  
>>>> 
>>>> Best,
>>>>  
>>>> 
>>>> Volker
>>>>  
>>>> 
>>>>  
>>>>  
>>>> 
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>>>> 
>>>> Am 15.02.2018 um 02:36 schrieb allison nixon:
>>>>  
>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> Hi everyone, 
>>>>>  
>>>>>  
>>>>> 
>>>>>  
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> I have already begun to hear unrest from my colleagues who work in infosec
>>>>> and network operations about the degradation of WHOIS, as registrars have
>>>>> already begun to act on their own, stripping everything and blocking bulk
>>>>> queriers on domains frequently used for attacks. Every day of additional
>>>>> uncertainty equals an additional day of victimization.
>>>>>  
>>>>>  
>>>>> 
>>>>>  
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> Why has no one approached the DPAs with the evidence of security purposes
>>>>> for WHOIS? How much network degradation will we tolerate before someone
>>>>> bothers to give them a little hint? How many more judgments from the DPAs
>>>>> are we going to read that display clear ignorance of all legitimate
>>>>> cybersecurity purposes? Did no one see this coming?
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>>  
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> Since we are talking about cost benefit analysis, here is a quick one I
>>>>> just did that I would like to share with the group. I did a quick look for
>>>>> the value of the domain registration industry as a whole. Seems to be ~$4
>>>>> billion. The losses incurred by the WanaCry malware are estimated to be at
>>>>> ~$8 billion. A single security incident destroying value equal to double
>>>>> your entire industry.
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>>  
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> In May 2017, the FBI stated that over three years the "business email
>>>>> compromise" scams have topped ~$5 billion in losses, which would be
>>>>> slightly more than one domain-industry unit of value, and WHOIS is crucial
>>>>> to fighting it.
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>>  
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>>>>> 
>>>>> source: 
>>>>> https://www.reuters.com/article/us-cyber-lloyds-report/global-cyber-attack
>>>>> -could-spur-53-billion-in-losses-lloyds-of-london-idUSKBN1A20AB
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> source: 
>>>>> https://cira.ca/factbook/domain-industry-data-and-canadian-Internet-trends
>>>>> /domain-name-industry
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>> source: 
>>>>> https://www.csoonline.com/article/3195010/security/bec-attacks-have-hit-th
>>>>> ousands-top-5-billion-in-losses-globally.html
>>>>>  
>>>>>  
>>>>>  
>>>>> 
>>>>>  
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>>>>>  
>>>>>  
>>>>> 
>>>>> Remember, the whole point of GDPR is to force companies to act with more
>>>>> social responsibility.
>>>>>  
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>>>>> 
>>>>>  
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>>>>>  
>>>>> 
>>>>> On Wed, Feb 14, 2018 at 6:08 PM, Rubens Kuhl <rubensk at nic.br> wrote:
>>>>>  
>>>>>>  
>>>>>>  
>>>>>> 
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>>>>>> 
>>>>>> 
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>>>>>>  
>>>>>>>  
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>>>>>>> 
>>>>>>> On 14 Feb 2018, at 20:49, John Horton <john.horton at legitscript.com>
>>>>>>> wrote:
>>>>>>>  
>>>>>>>  
>>>>>>>  
>>>>>>>  
>>>>>>>  
>>>>>>>  
>>>>>>>  
>>>>>>> 
>>>>>>> Hmm, well, perhaps it's because I work for a company that processes
>>>>>>> quite a bit of data with a combination of algorithms and some human
>>>>>>> review, but I feel pretty confident that there are ways to simplify that
>>>>>>> with magic algorithms and forms.
>>>>>>>  
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>>>>>> 
>>>>>>  
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>>>>>>  
>>>>>> 
>>>>>> Magic algorithms are fine in pattern detection because there is always a
>>>>>> human review at some point or the cost of error is low, like in raising
>>>>>> an abuse case that contains wording like supposedly", "allegedly" etc. In
>>>>>> this case, every false negative comes with a tremendous liability.
>>>>>>  
>>>>>>  
>>>>>>  
>>>>>> 
>>>>>>  
>>>>>>  
>>>>>>  
>>>>>>  
>>>>>> 
>>>>>> Also, if machine-learning technology and deep pockets for lawsuits become
>>>>>> a requirement for being a registrar, you can count on the number of
>>>>>> registrars dropping to single digits.
>>>>>>  
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>>>>>> 
>>>>>> Rubens
>>>>>>  
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>>>>>> 
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>>>>>> 
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>>>>>>  
>>>>>> 
>>>>>> _______________________________________________
>>>>>>  gnso-rds-pdp-wg mailing list
>>>>>>  gnso-rds-pdp-wg at icann.org
>>>>>>  https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>>  
>>>>>  
>>>>>  
>>>>> 
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>>>>>  
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>>>>>  
>>>>> -- 
>>>>>  
>>>>>  
>>>>> 
>>>>> _________________________________
>>>>>  Note to self: Pillage BEFORE burning.
>>>>>  
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>>>>>  
>>>>> 
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>>>>>  
>>>>>  
>>>>> _______________________________________________
>>>>>  
>>>>> gnso-rds-pdp-wg mailing list
>>>>>  
>>>>> gnso-rds-pdp-wg at icann.org
>>>>>  
>>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>>  
>>>>  
>>>>  
>>>>  
>>>>  
>>>>  
>>>> _______________________________________________ gnso-rds-pdp-wg mailing
>>>> list gnso-rds-pdp-wg at icann.org
>>>> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg
>>>>  
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