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

Fri Feb 16 12:22:11 UTC 2018

Nathalie, I don’t want to venture a guess at which bits of information are needed to determine web site trustworthiness, but I can tell you what’s implemented for demonstration purposes in my ccTLD (.cc and .tv) RDAP pilot. We have three access tiers:

1.      Unauthenticated access: the client receives basic information to confirm domain registration and delegation. Things like name servers, registrar info, etc.
2.      Basic access: the client authenticates with a “free, easy to acquire” credential like a Gmail or Hotmail email address (Google and Microsoft already support the underlying technology and nothing special is required). At this tier the client will receive additional information like registration and expiration dates, but no contact information.
3.      Authorized access: the client authenticates with a credential provided by one of a small number of identity provider partners that my RDAP implementation recognizes. My team is running one such provider, as are the folks at CZNIC. This is analogous to the “accredited” entities that we’ve been talking about. At this tier the client receives everything, including contact data.

As I said, this is just an example. The data available at any tier and the tiers in which various actors fit are significant topics of policy discussion.  The system can be made to work in such a way that a registrant or their delegate is indeed duly and fully authorized to see everything.

I’ve made the offer on this list before and I’ll make it again: I’ll provide a credential to anyone on this list who wants to see how how gated access can work with RDAP. Just ask and I’ll get you set up. We are working to add this feature to our gTLD pilot “soon”.

Scott

From: gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of nathalie coupet via gnso-rds-pdp-wg
Sent: Friday, February 16, 2018 12:19 AM
To: RDS PDP WG <gnso-rds-pdp-wg at icann.org>
Subject: [EXTERNAL] Re: [gnso-rds-pdp-wg] Equifax hack worse than previously thought: Biz kissed goodbye to card expiry dates, tax IDs etc

To technical people on this list:

In a tiered-system with authenticated access, how could the general public satisfy authentication requirements and what would those be, in order to have access to information about the trustworthiness of a website (what would this data be)?

Would it be possible to mandate someone who is duly authorized within the registrar to look up the data on her behest? Is there a way to automatize this process?

Personal thought: I keep on thinking we will find a silver bullet in the principles set by the law of the sea, the mechanisms of the EEZ or natural law. Still looking.

Thanks,

Nathalie

On Thursday, February 15, 2018 7:59 PM, Chuck <consult at cgomes.com> wrote:

Good points Chris.  Thanks again.

Chuck

From: Chris Pelling [mailto:chris at netearth.net]
Sent: Thursday, February 15, 2018 1:16 PM
To: Chuck <consult at cgomes.com>
Cc: Stephanie Perrin <stephanie.perrin at mail.utoronto.ca>; gnso-rds-pdp-wg <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

No issue Chuck, although, June is very optimistic in my opinion simply because the month prior - all hell breaks loose with GDPR :)  At least if we look at October, we can get the info out to as many DPA's as poss to get them there, plus, being Barcelona, it will be a lot cheaper for the countries to send them to Spain than the other side of the world (as governmetns dont like paying for very much to start with) :)

Kind regards,

Chris

  _____

From: "Chuck" <consult at cgomes.com<mailto:consult at cgomes.com>>
To: "Chris Pelling" <chris at netearth.net<mailto:chris at netearth.net>>
Cc: "Stephanie Perrin" <stephanie.perrin at mail.utoronto.ca<mailto:stephanie.perrin at mail.utoronto.ca>>, "gnso-rds-pdp-wg" <gnso-rds-pdp-wg at icann.org<mailto:gnso-rds-pdp-wg at icann.org>>
Sent: Thursday, 15 February, 2018 21:12:23
Subject: RE: [gnso-rds-pdp-wg] Equifax hack worse than previously thought:        Biz kissed goodbye to card expiry dates, tax IDs etc

My mistake Chris.  Thanks for setting me straight.  I am probably too optimistic, but it would be nice if it could happen in Panama in June.

Chuck

From: Chris Pelling [mailto:chris at netearth.net]
Sent: Thursday, February 15, 2018 1:10 PM
To: Chuck <consult at cgomes.com<mailto:consult at cgomes.com>>
Cc: Stephanie Perrin <stephanie.perrin at mail.utoronto.ca<mailto:stephanie.perrin at mail.utoronto.ca>>; gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org<mailto: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

Hi Chuck,

Barcelona is ICANN 63 in October, in June its ICANN 62 in Panama City : https://www.google.co.uk/search?hl=en&q=icann+meetings+2018&meta=

Kind regards,

Chris

  _____

From: "Chuck" <consult at cgomes.com<mailto:consult at cgomes.com>>
To: "Stephanie Perrin" <stephanie.perrin at mail.utoronto.ca<mailto:stephanie.perrin at mail.utoronto.ca>>, "gnso-rds-pdp-wg" <gnso-rds-pdp-wg at icann.org<mailto:gnso-rds-pdp-wg at icann.org>>
Sent: Thursday, 15 February, 2018 18:14:24
Subject: Re: [gnso-rds-pdp-wg] Equifax hack worse than previously thought:        Biz kissed goodbye to card expiry dates, tax IDs etc

Because of the long lead time for scheduling workshops, it’s not too early to explore the value of one in Barcelona in June.  It would be helpful if we could get to our charter question on Gated Access well before then if possible.

Chuck

From: gnso-rds-pdp-wg [mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of Stephanie Perrin
Sent: Thursday, February 15, 2018 9:45 AM
To: gnso-rds-pdp-wg at icann.org<mailto: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

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 | GoDaddy™

   sbockey at godaddy.com<mailto:sbockey at godaddy.com>  480-366-3616

   skype: sbockey

   This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.

   From: gnso-rds-pdp-wg <gnso-rds-pdp-wg-bounces at icann.org><mailto:gnso-rds-pdp-wg-bounces at icann.org> on behalf of Volker Greimann <vgreimann at key-systems.net><mailto:vgreimann at key-systems.net>
   Date: Thursday, February 15, 2018 at 4:30 AM
   To: Greg Shatan <gregshatanipc at gmail.com><mailto:gregshatanipc at gmail.com>
   Cc: "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] 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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