[IRT.RegDataPolicy] [Ext] RE: Additional Thoughts Re yesterday's Rec. 7 discussion

Tue Sep 3 14:26:58 UTC 2019

Dennis,

Thanks for raising this via email and the effort to clarify potential confusion.  Before responding directly to the questions posed, I think it may be helpful for those not on the Phase 1 Working Group to clarify the difference between the data elements workbooks (referenced in the text of Recommendation #7 and included in Annex D) and the data elements matrix created by ICANN staff.  Note Section 3.4 of the EPDP team approach (found on page 30 in the Final Report):

The EPDP Team realized the need to review each of the data elements collected, the purpose for its processing, and the legal basis for that data processing. This work resulted in the creation of the Data Elements Workbooks, which bring together purpose, data elements, processing activities, lawful basis for processing and responsible parties. For the Data Element Workbook for each purpose identified by the EPDP Team, see Annex D.

Annex D covers pages 92-147 in the final report and contains workbooks 1A, 1B, 2, 3, 4A, 4B, 5, 6 and 7.

To create a comprehensive view of the primary processing activities (collection by Registrar, collection by Registry, transfer from Registrar to Registry and publication), staff created the data elements matrix document.  This spreadsheet rolls up the tables from each data element workbook purpose into a single view.  The (collection/transfer/disclosure) logic column for each processing activity in the data elements matrix neatly color codes each data element as either Required (green), Optional (yellow) or not selected (red).  The Required (green) and Optional (yellow) data elements were then extracted from that column and included in the body of the final report.

For example, for Recommendation #7, the Working Group determined that the “Domain Name” data element field is required to be transferred to the registry, and that is reflected with a green (required) indication in the transfer logic column on pages 9 and 44 in the Final Report.  In the data elements workbooks (Annex D), the “Domain Name” data element is marked with an “R” (Required) under purpose 1A (page 98), purpose 1B (page 103), purpose 2 (page 108), purpose 3 (page 114), purpose 5 (page 133) and purpose 6 (page 141).  Looking at the final (1.8) version of the data elements matrix (https://community.icann.org/display/EOTSFGRD/e.+Data+Elements+Workbooks), the “summary_transfer_Rr_Ry” tab reflects the “Domain Name” data element as being Required “R” for each of those purposes and the “Transfer Logic” column is green (Required).

In contrast, for Recommendation #7, the Working Group determined that the “Registrant Email” data element is not required to be transferred to the Registry, and this is reflected with a yellow (optional) indication in the transfer logic column on pages 9 and 44 in the Final Report.  In the data elements workbooks (Annex D), the “Registrant Email” data element is marked as “O-CP” (optional) under purpose 1B (page 104).  More specifically “O-CP” means optional for the contracted party subject to the contracted party’s terms and conditions.  It is also listed as “O-CP” (optional) for purposes 2, 3, 5 and 6.  In the final (1.8 version) of the data elements matrix the “summary_transfer_Rr_Ry” tab reflects the “Registrant Email” as being “O-CP” (optional) for each of those purposes and the “Transfer Logic” column is yellow (optional).

Regarding Question 1 below.  You seem to be questioning, based on the RySG group statement included as part of Annex G of the final report , whether the aggregate data elements workbooks included in the Final Report at Annex D should be used  to guide the requirement for our policy.

I’m not really sure why this is a question.  The text of Recommendation #7 references the data elements identified in aggregate from the data elements workbooks.   The RySG’s comment listed in Annex G is not a policy recommendation adopted by the Phase 1 working group.  Actually, the statement on page 171 was submitted by me against an earlier (11 Feb draft) of the Final Report (https://mm.icann.org/pipermail/gnso-epdp-team/2019-February/001684.html.  In some cases the RySG feedback was adopted by the Phase 1 working group and made it into the Final Report, but that was not the case for the statement on page 171, and the data elements workbooks  were left in and included in their entirety as Annex D in the Final Report.   From what I can tell, and as I outlined above, the final version of the data elements matrix, the aggregate data elements workbooks in Annex D, and the text of Recommendation # 7 in the Final Report all provide the same information as to which fields are Required and Optional for transfer from Registrar to Registry.  Given that they are the same, I’m not sure why this is even a question.  As I mentioned a few weeks ago during our meeting, the IRT’s mandate is to implement the EPDP Phase 1 Final Report, including Recommendation 7 as adopted by the EPDP team, approved by the GNSO Council and adopted by the ICANN Board.

For Question 2 – the final (1.8) version of the Data Elements Matrix must be used (rather than the 1.4 version the final report links to).  Berry has confirmed that this was an administrative miss which I think is sufficient.  A comparison of the aggregate data elements workbooks found in Annex D of the Final Report and version 1.8 of the Data Elements Matrix further confirms that it is the correct version.

Thank you,

Marc

From: Dennis Chang <dennis.chang at icann.org>
Sent: Friday, August 30, 2019 2:20 PM
To: Mark Svancarek (CELA) <marksv at microsoft.com>; theo geurts <gtheo at xs4all.nl>; Anderson, Marc <mcanderson at verisign.com>; irt.regdatapolicy at icann.org
Subject: [EXTERNAL] Re: [Ext] RE: [IRT.RegDataPolicy] Additional Thoughts Re yesterday's Rec. 7 discussion

Dear IRT,

To spur continued IRT discussion on Rec 7,  clarify potential confusion, and align assumptions, I am asking two questions.

Question 1:  In consideration of Mark’s comment below, “workbooks themselves are non-definitive (p171),” should the workbook used to guide the requirement for our policy?

Here is the full paragraph from p171. “Further, the citation of the Workbooks in Recommendation #7 should be removed. The agreed aggregate data set is presented in the text of the Recommendation as that was the agreed-upon text. The Workbooks are informational and should not be incorporated by reference.

Question 2:  If the answer is yes to the question above, can the IRT agree to accept the version 1.8 found in the wiki rather than the version 1.4 that the Final Report links to?

It’s important that the IRT’s decision on this be documented here. Please note that
“20 Feb - Data Elements Matrix_v1.8.xlsx<https://community.icann.org/download/attachments/96207076/Data%20Elements%20Matrix_v1.8.xlsx?version=1&modificationDate=1550683203000&api=v2>” is the last entry found on the Data Elements Workbooks page: https://community.icann.org/display/EOTSFGRD/e.+Data+Elements+Workbooks

Please reply with your answers, comments, or question.

Thanks

Dennis Chang

From: "Mark Svancarek (CELA)" <marksv at microsoft.com<mailto:marksv at microsoft.com>>
Date: Thursday, August 8, 2019 at 2:20 PM
To: theo geurts <gtheo at xs4all.nl<mailto:gtheo at xs4all.nl>>, "Anderson, Marc" <mcanderson at verisign.com<mailto:mcanderson at verisign.com>>, Dennis Chang <dennis.chang at icann.org<mailto:dennis.chang at icann.org>>, "irt.regdatapolicy at icann.org<mailto:irt.regdatapolicy at icann.org>" <irt.regdatapolicy at icann.org<mailto:irt.regdatapolicy at icann.org>>
Subject: [Ext] RE: [IRT.RegDataPolicy] Additional Thoughts Re yesterday's Rec. 7 discussion

I note that RySG says that the workbooks themselves are non-definitive (p171).  So even though the data elements matrix document is on the “workbooks wiki”, it’s the matrix document rather than the workbooks themselves which should be used, I think.

For clarity we should use the Data Elements Matrix document v1.8, if in fact that is the final version.

From: IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org<mailto:irt.regdatapolicy-bounces at icann.org>> On Behalf Of theo geurts
Sent: Thursday, August 8, 2019 11:54 AM
To: Anderson, Marc <mcanderson at verisign.com<mailto:mcanderson at verisign.com>>; dennis.chang at icann.org<mailto:dennis.chang at icann.org>; irt.regdatapolicy at icann.org<mailto:irt.regdatapolicy at icann.org>
Subject: Re: [IRT.RegDataPolicy] Additional Thoughts Re yesterday's Rec. 7 discussion

Thanks for keeping us on the same page and on track Marc.

I think your suggestion to stick with the workbooks from the final report makes the most sense.

Theo

On 8-8-2019 20:25, Anderson, Marc via IRT.RegDataPolicy wrote:

   IPT and IRT members,

   The version 1.4 of the Data Elements Matrix that Margie references is an old version.  The correct final version of the Data Elements Matrix is 1.8 and can be found on the Data Elements Workbooks page of the ePDP wiki:

   https://community.icann.org/display/EOTSFGRD/e.+Data+Elements+Workbooks [nam06.safelinks.protection.outlook.com]<https://urldefense.proofpoint.com/v2/url?u=https-3A__nam06.safelinks.protection.outlook.com_-3Furl-3Dhttps-253A-252F-252Fcommunity.icann.org-252Fdisplay-252FEOTSFGRD-252Fe.-252BData-252BElements-252BWorkbooks-26data-3D02-257C01-257Cmarksv-2540microsoft.com-257C8f230e035a7f4e74603808d71c31e341-257C72f988bf86f141af91ab2d7cd011db47-257C1-257C0-257C637008872914475857-26sdata-3DI1Md816vu6s4kEhafPdMnFMSVybZpSFxJdqZNfRRYUA-253D-26reserved-3D0&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=dqLP1wJqBvDSYLKrSEaAkCi_Kv0Mk5D_d32n29DHCN8&m=y6czU1DrDU0edDElRKK8ScLIcgbRHomRQhRdN6koJco&s=36J0xZSvvpnazCdkOmqv11ztj_HttfPiq8gB5ZEBv9E&e=>

   In looking at the final report, I see that the link provided for “illustrative purposes” at the end of recommendation #7 (page 10) goes to the old version 1.4 of the Data Elements Matrix.  I hadn’t noticed this before as I have been referring exclusively to the Data Element workbooks found in Appendix D (which start on page 92 of the Final Report).

   I suggest everyone make sure you are looking at the correct version 1.8 of the Data Elements Matrix, or better yet stick with the workbooks contained in the Final Report (Appendix D).  These are consistent with version 1.8 of the Matrix document.

   Best,

   Marc

   From: IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org><mailto:irt.regdatapolicy-bounces at icann.org> On Behalf Of Margie Milam
   Sent: Thursday, August 8, 2019 1:07 PM
   To: Dennis Chang <dennis.chang at icann.org><mailto:dennis.chang at icann.org>; IRT.RegDataPolicy <irt.regdatapolicy at icann.org><mailto:irt.regdatapolicy at icann.org>
   Subject: [EXTERNAL] [IRT.RegDataPolicy] Additional Thoughts Re yesterday's Rec. 7 discussion

    Hi All –

   After our IRT call, I reread Rec 7 and the supporting appendices, per Marc A’s suggestion.   Rec 7 links to the Data Elements Matrix on Page 10 (attached for your convenience) , which clearly describes what data is required to be transferred to the registry from the registrar, and what data is optional.

   The 3rd page of the Data Elements Matrix (Transfer from Registrar to Registry), clearly notes an R (Required) for the contact data fields that are required to be transferred, which include all of the registrant contacts except for:

   *    the Org field
   *    the Tech Contact Name and Email Address ,

   which are listed as O-RNH (Optional for the Registered Name Holder) for the purposes listed on the matrix (including, Purpose 2).

   As a result, the new policy continues the “thick WHOIS” requirements and our implementation needs to be consistent with Thick WHOIS, especially in light of the Board’s resolution  and its anguage in the scorecard.

   Also, please note that this data elements matrix is also relevant to our prior discussion regarding what “optional” means with regard to the Tech Contact and the Org Contact in Rec. 5, footnote 7.   Rec 5 also links to this Data Elements Matrix, and clarifies whether a field is optional to the registrar, registry or registered name holder.  Since the data elements of Tech Field and Org Field are clearly marked as O-RNH and do not include O-Rr (Optional for Registrar), our prior conclusions on Rec .5 need to be revisited in light of this documentation.

   I propose we discuss this at our next IRT meeting.

   All the best,

   Margie

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