[Ws2-transparency] Draft WS2 Transparency Document

[Schaefer, Brett]

Michael,

Well done, I appreciate the effort made to draft this document. I’m looking forward to seeing the next version with more detail on proactive disclosure policies. I have a few brief comments:


·         The sentence on page 9 starting “Another way to facilitate… “ seems incomplete.

·         As you correctly note, ICANN should provide “provide reasonable assistance to requesters who need it, particularly where they are disabled or unable to identify adequately the information they are seeking.” From what I understand, ICANN sometimes denies DIDP requests if the information is already publicly available. Not all requests come from individuals or businesses that are intimately familiar with ICANN. They may not know where to find the information sought or how that information is categorized or referred to (jargon) inside ICANN. In these circumstances, I think reasonable assistance should encompass a simple response informing the requester where to find the information they are seeking.

·         On proactive disclosure policies, I think we need to be clear that “political activities” includes venders hired to provide education/engagement services, e.g. those provided by Rice Hadley Gates LLC and Albright Stonebridge Group LLC, and similar activities.

·         On proactive disclosure policies, I propose that ICANN adopt a policy of not contracting with any vendor insisting on confidentiality clauses that preclude disclosure of fundamental information, such as services contracted and pricing, to the ICANN community.

Best,

Brett

From: ws2-transparency-bounces at icann.org [mailto:ws2-transparency-bounces at icann.org] On Behalf Of Michael Karanicolas
Sent: Tuesday, October 18, 2016 10:33 AM
To: ws2-transparency at icann.org
Subject: [Ws2-transparency] Draft WS2 Transparency Document

Hello all,

Please find attached a first draft of our document, including Recommendations for the DIDP, proactive disclosure and whistleblower protection. Thanks so much to everyone who submitted ideas or comments, and particular thanks to Barbara Wanner and my co-rapporteur Chris Wilson, who led on drafting sections 2 and 3.

A couple of things to note. First, right now the document is a bit of a mashup between the different contributions. I still need to go through again, just to harmonize the different sections and make it a bit more coherent. Second, the proactive disclosure section right now only addresses ICANN's engagement with governments, so I also need to beef that up a bit, to add in some things about budget transparency, and potentially other areas that should be published.

We are set to have a call to discuss this at the end of the week, at 3 pm EST, so please try and look through it before then. We are keen to hear your inputs! We are also supposed to circulate more broadly to the other groups by end of the week, so if there are major substantive issues to raise, starting the conversation sooner would be preferable.

Best wishes, look forward to hearing from you,

Michael Karanicolas
Senior Legal Officer
Centre for Law and Democracy

________________________________
Brett Schaefer
Jay Kingham Senior Research Fellow in International Regulatory Affairs
Margaret Thatcher Center for Freedom Davis Institute for National Security and Foreign Policy
The Heritage Foundation
214 Massachusetts Avenue, NE
Washington, DC 20002
202-608-6097
heritage.org<http://heritage.org/>
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