[gnso-rds-pdp-wg] Equifax hack worse than previously thought: Biz kissed goodbye to card expiry dates, tax IDs etc

Stephanie Perrin stephanie.perrin at mail.utoronto.ca
Thu Feb 15 17:44:32 UTC 2018


I agree with Sara wholeheartedly.  I would like to propose a workshop at 
the Barcelona meeting to discuss accreditation requirements for 
cybersecurity an IP actors who want to retain access to personal data in 
a tiered access solution.  Release of data in such a system will require 
standards, and I (as mentioned in Abu, on the public panel on GDPR, and 
in my own comments on the 3 models) I think we should get on with 
developing those standards, preferably ISO standards with possibility 
for independent audit.

Stephanie Perrin

On 2018-02-15 11:34, Sara Bockey wrote:
>
> Our job is now to cooperate in good faith to build a new universal 
> system that still fits most needs but also takes data protection as 
> its core principle.
>
> EXACTLY! And what’s lacking from most of our conversations are 
> SOLUTIONS.  We understand that many of you have come to rely on 
> various types of data from WHOIS.  We get it.  We’ve heard you.  What 
> we have NOT heard is “we understand the changing landscape, and while 
> we are concerned about losing X data, perhaps if we do Y, we can 
> improve RDS and still have access OR if we do Z, we can _________.”
>
> Given the number of really smart people on this list, I am frustrated 
> by the lack of innovative, forward thinking.  Change doesn’t have to 
> be scary.  Change can be better - an improvement.  We need to stop 
> with the myopia.  We need to stop looking backward.  We need to stop 
> demonizing. If you are not saying something NEW, something to move 
> this PDP _forward_, you are part of the problem.
>
> Sara
>
> *sara bockey*
>
> *sr. policy manager | **Go**Daddy^™ *
>
> *sbockey at godaddy.com <mailto:sbockey at godaddy.com> 480-366-3616*
>
> *skype: sbockey*
>
> //
>
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> *From: *gnso-rds-pdp-wg <gnso-rds-pdp-wg-bounces at icann.org> on behalf 
> of Volker Greimann <vgreimann at key-systems.net>
> *Date: *Thursday, February 15, 2018 at 4:30 AM
> *To: *Greg Shatan <gregshatanipc at gmail.com>
> *Cc: *"gnso-rds-pdp-wg at icann.org" <gnso-rds-pdp-wg at icann.org>
> *Subject: *Re: [gnso-rds-pdp-wg] Equifax hack worse than previously 
> thought: Biz kissed goodbye to card expiry dates, tax IDs etc
>
> That would be problematic, as you should know, since there is no clear 
> cut line of what would constitute over-enforcement or 
> under-enforcement. Well, the latter will resolve itself due to the 
> incoming DPA actions.
>
> I also never heard of fees to be paid into a fund by those simply 
> trying to remain compliant with their applicable laws.
>
> Contracted parties have been stating for years, if not over a decade 
> that publication whois details in the current form and shape is 
> problematic from a data protection perspective. We have repeatedly 
> tried to drive home the point that the current system is not 
> sustainable. We were ignored or ridiculed, or asked to get sued to 
> prove our point. Now that we are forced to take action, everybody is 
> protesting as if this were something new. It is not. Now we have to do 
> a short-term fix, that will hurt more than it would have needed to if 
> everyone had cooperated in good faith to reform whois years ago. The 
> status quo will change.
>
> Our job is now to cooperate in good faith to build a new universal 
> system that still fits most needs but also takes data protection as 
> its core principle.
>
> Volker out!
>
> Am 15.02.2018 um 05:14 schrieb Greg Shatan:
>
>     In a similar vein, ICANN could establish an “Over-enforce the GDPR
>     Fund,” in which everyone who thinks the GDPR’s data blackout
>     should be extended to the data of non-EU and legal persons would
>     pay in, and it would be used to defray the expenses incurred by
>     those who should have access to information and instead must
>     expend additional time, money and effort, and often incur
>     additional harm, due GDPR over-enforcement.
>
>     On Wed, Feb 14, 2018 at 5:03 AM Volker Greimann
>     <vgreimann at key-systems.net<mailto:vgreimann at key-systems.net>> wrote:
>
>         Maybe you are hitting on something here.
>
>         ICANN could just establish a "Leave-Whois-as-it-is" legal
>         defense fund. Everyone who argues that whois should remain as
>         it is has to pay into that fund and everyone who is fined by
>         data protection violations can take the fines and their legal
>         costs out of that fund. Of course, that would necessitate huge
>         investments to set up the fund from mainly volunteer
>         organizations that do not actually have the means to support it.
>
>         Best,
>
>         Volker
>
>         Am 14.02.2018 um 02:21 schrieb Rubens Kuhl:
>
>
>
>                 On 13 Feb 2018, at 20:32, John Horton
>                 <john.horton at legitscript.com<mailto:john.horton at legitscript.com>>
>                 wrote:
>
>                 Thanks, Rubens -- I don't agree with that
>                 interpretation. (I think you mean the Q&A memo Section
>                 2, right?) See memo
>                 here<https://www.icann.org/en/system/files/files/gdpr-memorandum-part2-18dec17-en.pdf>.
>                 Let me know if you meant the first or a different one.
>
>             It's exactly that memo.
>
>             Since you don't agree, does that mean that your
>             organisation is willing to pay every GDPR fine contracted
>             parties get from following your interpretation ? Because
>             if you are unwilling to do that, then your belief in that
>             interpretation is not rock solid.
>
>             What I can tell you is that this risk has been flagged by
>             that paper, by the eco model and by internal analysis of
>             some registries, all independently of each other; which
>             means you will likely see a good number of contracted
>             parties following exactly the path I outlined in order to
>             mitigate this risk.
>
>             If you see things differently, get Europeans DPAs to put
>             that in writing, and we are all good to go.
>
>             Rubens
>
>
>
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