[TSG-Access-RD] FW: [Ext] comment on the TSG draft

[Ram Mohan]

Thanks, Diana. Could I ask Andy and Scott to take a close look at the
comments below?



-Ram





*From:* Diana Middleton <diana.middleton at icann.org>
*Sent:* Wednesday, April 10, 2019 11:47 AM
*To:* Technical Study Group RD <tsg-access-rd at icann.org>
*Subject:* [TSG-Access-RD] FW: [Ext] comment on the TSG draft



Dear all, comment received on the model below. Best, --Diana





*From: *"Chen, Tim" <tim at domaintools.com>
*Date: *Wednesday, April 10, 2019 at 10:42
*To: *"gdpr at icann.org" <gdpr at icann.org>
*Subject: *[Ext] comment on the TSG draft



Hi Ram/TSG Team,



I briefly reviewed the TSG document and had only this one comment if
useful:   It regards Section 4.1 "User Journey".



This section does not really seem to represent a typical user journey.  I
would go so far as to say Section 4 doesn't seem to have the same
thoroughness as the rest of the document.



The typical User Journey to me might be something like this:

-User needs access to non-public Whois data on one or more domains for
legitimate purpose

-User discovers ICANN service

-User applies for credentials, and is able to understand what evidence is
needed and how to apply and how long that process takes.

-User applies.

-User receives credentials or a rejection or redirect in a reasonable
amount of time (I'd prefer to be specific here)

-User is made aware of what materials he/she needs to submit for a properly
formatted request for non-public registration data

-User uses credentials in concert with specific investigation materials to
request non-public Whois data on one or more domains

-User receives non-public Whois data or a rejection or redirect in a
reasonable amount of time (I'd prefer to be specific here)



The TSG should consider either re-writing the User Journey to be consistent
with the level of detail and quality in other parts of this 22 page
document, or delete it.   What exists there now is actually damaging bc it
seems to be an incomplete and somewhat random list of a very small number
of actions that *may* be part of this service.  For example:

-correlation is not more than a possible future concept at this point, yet
it is one of four bullets here.

-"was the name just registered" ?  Create Date is still in public Whois I
believe.  Therefore this is not a likely query for this service or at a
minimum can be accomplished outside of this service.

-the term 'abusive registrant'  is not a defined term and lacks any context
or specificity.  Certainly it is something a user might pursue but there
are many such concepts that would fall in this category, most of which are
not listed in 4.1.



If 4.1 is supposed to be just a few examples of certain query types or
'user journeys' that may be supported, fine.  But make that clear.  What is
there right now certainly does not seem to be a "User Journey" nor the most
common use case.



Tim Chen

DomainTools
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