Dear Bruce,

As someone who has spent some time combing through the different responses that ICANN files to the various DIDP requests, my findings are slightly different, and have been posted earlier.

While ICANN does link one to an innumerable array of documents that are publicly available, many times, there is little or no connection between the information one seeks and the publicly available documents that are provided. For instance, I have asked a few questions on registrar/registry audits, specifically seeking individual contracted party audit reports in cases where there have been breaches or discrepancies. However, the response contains a large number of links explaining ICANN's three-year-audit process in great detail, and at the end has a rejection of my actual request on the basis of certain of their extremely vast and broad grounds for non-disclosure. I like to refer to this as ICANN's tendency towards documentary obfuscation where they aren't actually giving you the information that you need, but are drowning you in documents anyway.

That 66 is a figure that we might need to scrutinise closer in terms of how effective those disclosures actually have been.

Warm Regards

Padmini

Programme Associate, Internet Governance

Centre for Internet and Society, Bangalore, India

Padmini Baruah

V Year, B.A.LL.B. (Hons.)

NLSIU, Bangalore

On Thu, Oct 29, 2015 at 12:16 PM, Bruce Tonkin <Bruce.Tonkin@melbourneit.com.au> wrote:

Hello Greg,

>> 6333. The accounting books and records and minutes of proceedings
of the members and the board and committees of the board shall be
open to inspection upon the written demand on the corporation of any
member at any reasonable time, for a purpose reasonably related to
such person's interests as a member.

The minutes are basically published today. The only minutes apparently that are not posted are compensation committee minutes – but even then we could at least note the items discussed without necessarily disclosing some personal information.

With regard to financials– we are already moving towards the same standards as publicly listed companies in the USA. We now provide quarterly financial reporting, and a quarterly call where the community can question the CEO and the CFO on the income and expenditure. It would not be normal to provide people with access to the raw accounting system (in this case Great Plains) – which would include information on payments to all staff etc.

We do use an external auditor to validate our financials and processes once per year.

If there is a community concern about a particular financial matter (e.g concern about whether procurement policies were being followed) – then I think it would be more appropriate if the single legal entity that represents the community powers has the right to appoint an external auditor to validate any particular process or numbers and report back to the community. Audit firms have the appropriate skills to analyse financial accounting records and also have appropriate procedures in place for confidentiality.

I think we should be focussing on improving the processes we already have. I advocated moving to quarterly financial reporting, and I have certainly been a strong advocate of making things as public as possible, and welcome suggestions for improving our processes.

Regards,
Bruce Tonkin

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