URGENT: DRAFT ALAC Statement on the EPDP Phase 1 Final Report
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report. I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns. The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues. THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency. Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline. WORD and PDF formats are attached. Alan
Thank you Alan I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments Holly
On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan <ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
I agree with everything. particularly with the observation about email. Regards Alberto Enviado desde mi iPhone El 15 feb. 2019, a la(s) 00:17, Holly Raiche <h.raiche@internode.on.net> escribió:
Thank you Alan
I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments
Holly
On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan <ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
Thanks Holly. Alan At 14/02/2019 10:17 PM, Holly Raiche wrote: Thank you Alan I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments Holly On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca<mailto:alan.greenberg@mcgill.ca> > wrote: As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report. I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns. The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues. THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency. Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline. WORD and PDF formats are attached. Alan <ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org<mailto:ALAC@atlarge-lists.icann.org> https://atlarge-lists.icann.org/mailman/listinfo/alac At-Large Online: http://www.atlarge.icann.org<http://www.atlarge.icann.org/> ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA... )
Thanks - I cannot join this evening’s (CET) CPWG call and therefore want to express my support for the statement. If it comes to a vote during the call then please include my explicit endorsement. Just a comment, and if not relevant then ignore, but I took the final report from 11 February that was sent to the GNSO council on the 12th as a reference to see what our concerns apply to. I am somewhat confused: - Rec#16 states ‘that Registrars and Registry Operators are permitted to differentiate between registrants on a geographic basis, but are not obligated to do so.’ Our response says ‘The report recommends that contracted parties will not need to perform any level of geographic differentiation due to the difficulty of determining the location of the registrant.’ I cannot find that argument (‘due to’) in the draft final report. However rec#5 requires registrars to a.o. collect address- incl country data from registrants. So on the one hand hand the data are collected and (should be) accurate, and on the other it is ‘difficult’ to ‘determine the location of the registrant’? - Rec#5 lists the ‘data elements to be collected where some data elements are automatically generated and, as indicated below, in some cases it is optional for the registered name holder to provide those data elements. The ‘tech fields’ (name, phone and email) in the ‘data elements’ table are not ‘indicated’ as being ‘optional’. Like for instance the ‘organization’ and ‘fax’ fields of the ‘registrant’ (= ‘opt.’) . Then there is a note ‘For the purpose of the Technical contact, which is optional for the Registered Name Holder to complete (and if the Registrar provides this option)’. Etc. Why are the technical contact data elements not labeled in the table as being ‘(opt.)’? thanks again, with regards Bastiaan *** Please note that this communication is confidential, legally privileged, and subject to a disclaimer: https://www.ams-ix.net/ams/email-disclaimer ***
On 15 Feb 2019, at 04:17, Holly Raiche <h.raiche@internode.on.net> wrote:
Thank you Alan
I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments
Holly
On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan <ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
At 15/02/2019 02:45 AM, Bastiaan Goslings wrote:
Thanks - I cannot join this evening’s (CET) CPWG call and therefore want to express my support for the statement. If it comes to a vote during the call then please include my explicit endorsement.
Thanks! If other ALAC Members are in the same position, a message of support prior to the meeting will allow us to know if there is sufficient support.
Just a comment, and if not relevant then ignore, but I took the final report from 11 February that was sent to the GNSO council on the 12th as a reference to see what our concerns apply to. I am somewhat confused:
- Rec#16 states ‘that Registrars and Registry Operators are permitted to differentiate between registrants on a geographic basis, but are not obligated to do so.’
Our response says ‘The report recommends that contracted parties will not need to perform any level of geographic differentiation due to the difficulty of determining the location of the registrant.’
I cannot find that argument (‘due to’) in the draft final report. However rec#5 requires registrars to a.o. collect address- incl country data from registrants. So on the one hand hand the data are collected and (should be) accurate, and on the other it is ‘difficult’ to ‘determine the location of the registrant’?
The contracted parties have said there is too much risk of incorrectly identifying whether GDPR is applicable to the registrant. We both have the same difficulty in reconciling these two facts. The other factor is that a registrar outside of the EU who has resellers "might" have a reseller in the EU (ie a "processor") without their knowledge be cause resellers can have resellers can have resellers... and the original registrar has no idea who they are. That should be fixed by requiring that they know!
- Rec#5 lists the ‘data elements to be collected where some data elements are automatically generated and, as indicated below, in some cases it is optional for the registered name holder to provide those data elements.
The ‘tech fields’ (name, phone and email) in the ‘data elements’ table are not ‘indicated’ as being ‘optional’. Like for instance the ‘organization’ and ‘fax’ fields of the ‘registrant’ (= ‘opt.’) . Then there is a note ‘For the purpose of the Technical contact, which is optional for the Registered Name Holder to complete (and if the Registrar provides this option)’. Etc. Why are the technical contact data elements not labeled in the table as being ‘(opt.)’?
I have pointed out that apparent discrepancy and presume it will be fixed. Alan
thanks again, with regards Bastiaan
*** Please note that this communication is confidential, legally privileged, and subject to a disclaimer: https://www.ams-ix.net/ams/email-disclaimer ***
On 15 Feb 2019, at 04:17, Holly Raiche <h.raiche@internode.on.net> wrote:
Thank you Alan
I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments
Holly
On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan
<ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________
ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
My support as well. Kaili ----- Original Message ----- From: "Alan Greenberg" <alan.greenberg@mcgill.ca> To: "Bastiaan Goslings" <bastiaan.goslings@ams-ix.net>; "Holly Raiche" <h.raiche@internode.on.net> Cc: "CPWG" <cpwg@icann.org>; "ALAC" <alac@atlarge-lists.icann.org> Sent: Friday, February 15, 2019 10:42 PM Subject: Re: [CPWG] [ALAC] URGENT: DRAFT ALAC Statement on the EPDP Phase 1 Final Report At 15/02/2019 02:45 AM, Bastiaan Goslings wrote:
Thanks - I cannot join this evening’s (CET) CPWG call and therefore want to express my support for the statement. If it comes to a vote during the call then please include my explicit endorsement.
Thanks! If other ALAC Members are in the same position, a message of support prior to the meeting will allow us to know if there is sufficient support.
Just a comment, and if not relevant then ignore, but I took the final report from 11 February that was sent to the GNSO council on the 12th as a reference to see what our concerns apply to. I am somewhat confused:
- Rec#16 states ‘that Registrars and Registry Operators are permitted to differentiate between registrants on a geographic basis, but are not obligated to do so.’
Our response says ‘The report recommends that contracted parties will not need to perform any level of geographic differentiation due to the difficulty of determining the location of the registrant.’
I cannot find that argument (‘due to’) in the draft final report. However rec#5 requires registrars to a.o. collect address- incl country data from registrants. So on the one hand hand the data are collected and (should be) accurate, and on the other it is ‘difficult’ to ‘determine the location of the registrant’?
The contracted parties have said there is too much risk of incorrectly identifying whether GDPR is applicable to the registrant. We both have the same difficulty in reconciling these two facts. The other factor is that a registrar outside of the EU who has resellers "might" have a reseller in the EU (ie a "processor") without their knowledge be cause resellers can have resellers can have resellers... and the original registrar has no idea who they are. That should be fixed by requiring that they know!
- Rec#5 lists the ‘data elements to be collected where some data elements are automatically generated and, as indicated below, in some cases it is optional for the registered name holder to provide those data elements.
The ‘tech fields’ (name, phone and email) in the ‘data elements’ table are not ‘indicated’ as being ‘optional’. Like for instance the ‘organization’ and ‘fax’ fields of the ‘registrant’ (= ‘opt.’) . Then there is a note ‘For the purpose of the Technical contact, which is optional for the Registered Name Holder to complete (and if the Registrar provides this option)’. Etc. Why are the technical contact data elements not labeled in the table as being ‘(opt.)’?
I have pointed out that apparent discrepancy and presume it will be fixed. Alan
thanks again, with regards Bastiaan
*** Please note that this communication is confidential, legally privileged, and subject to a disclaimer: https://www.ams-ix.net/ams/email-disclaimer ***
On 15 Feb 2019, at 04:17, Holly Raiche <h.raiche@internode.on.net> wrote:
Thank you Alan
I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments
Holly
On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan
<ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________
ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg
+1 On Fri, Feb 15, 2019, 13:59 Kan Kaili <kankaili@gmail.com wrote:
My support as well.
Kaili
----- Original Message ----- From: "Alan Greenberg" <alan.greenberg@mcgill.ca> To: "Bastiaan Goslings" <bastiaan.goslings@ams-ix.net>; "Holly Raiche" < h.raiche@internode.on.net> Cc: "CPWG" <cpwg@icann.org>; "ALAC" <alac@atlarge-lists.icann.org> Sent: Friday, February 15, 2019 10:42 PM Subject: Re: [CPWG] [ALAC] URGENT: DRAFT ALAC Statement on the EPDP Phase 1 Final Report
At 15/02/2019 02:45 AM, Bastiaan Goslings wrote:
Thanks - I cannot join this evening’s (CET) CPWG call and therefore want to express my support for the statement. If it comes to a vote during the call then please include my explicit endorsement.
Thanks! If other ALAC Members are in the same position, a message of support prior to the meeting will allow us to know if there is sufficient support.
Just a comment, and if not relevant then ignore, but I took the final report from 11 February that was sent to the GNSO council on the 12th as a reference to see what our concerns apply to. I am somewhat confused:
- Rec#16 states ‘that Registrars and Registry Operators are permitted to differentiate between registrants on a geographic basis, but are not obligated to do so.’
Our response says ‘The report recommends that contracted parties will not need to perform any level of geographic differentiation due to the difficulty of determining the location of the registrant.’
I cannot find that argument (‘due to’) in the draft final report. However rec#5 requires registrars to a.o. collect address- incl country data from registrants. So on the one hand hand the data are collected and (should be) accurate, and on the other it is ‘difficult’ to ‘determine the location of the registrant’?
The contracted parties have said there is too much risk of incorrectly identifying whether GDPR is applicable to the registrant. We both have the same difficulty in reconciling these two facts.
The other factor is that a registrar outside of the EU who has resellers "might" have a reseller in the EU (ie a "processor") without their knowledge be cause resellers can have resellers can have resellers... and the original registrar has no idea who they are. That should be fixed by requiring that they know!
- Rec#5 lists the ‘data elements to be collected where some data elements are automatically generated and, as indicated below, in some cases it is optional for the registered name holder to provide those data elements.
The ‘tech fields’ (name, phone and email) in the ‘data elements’ table are not ‘indicated’ as being ‘optional’. Like for instance the ‘organization’ and ‘fax’ fields of the ‘registrant’ (= ‘opt.’) . Then there is a note ‘For the purpose of the Technical contact, which is optional for the Registered Name Holder to complete (and if the Registrar provides this option)’. Etc. Why are the technical contact data elements not labeled in the table as being ‘(opt.)’?
I have pointed out that apparent discrepancy and presume it will be fixed.
Alan
thanks again, with regards Bastiaan
*** Please note that this communication is confidential, legally privileged, and subject to a disclaimer: https://www.ams-ix.net/ams/email-disclaimer ***
On 15 Feb 2019, at 04:17, Holly Raiche <h.raiche@internode.on.net> wrote:
Thank you Alan
I think you have captured the outcomes of the CPWG discussions very well. I am happy with this statement and have no further comments
Holly
On Feb 15, 2019, at 11:28 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan
<ALAC-Statement-v01.docx><ALAC-Statement-v01.pdf>_______________________________________________
ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki:
https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
At-Large Online: http://www.atlarge.icann.org ALAC Working Wiki:
https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALA...)
_______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ ALAC mailing list ALAC@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/alac
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Hello Alan, Thanks for sharing this which is good. A few minor editorials and comment: 1. "“that it would be difficult to argue that *that* processing to prevent DNS...." 2 "...Phase 2 will *be* address the deferred issues as..." 3. I am not sure why we say "we do not accept" certain issues yet we seem to end our statement by accepting the report. Since/if we have red-lines then we should clearly not accept the report as a whole. However if we can live with the report as indicated in the last paragraph then I suggest we modify the following: "To be specific, the results which we cannot accept are:...." So it doesn't contradict the acceptance stated in the last paragraph. That said, I agree with Gorge, that the element of choice/consent is being taken away from registrants in terms of what they want to provide and publish. It's election period in my country, my apologies as I won't be present at upcoming cpwg call Regards Sent from my mobile Kindly excuse brevity and typos On Fri, 15 Feb 2019, 01:28 Alan Greenberg <alan.greenberg@mcgill.ca wrote:
As discussed on the CPWG call yesterday, attached please find the draft statement to be attached to the report.
I believe that it addresses all of the issues we discussed and for which there was general concern. As decided, we will support the overall report, but note that some of the particular recommendations do not have our support. Others we will support but nevertheless have concerns.
The lack of focus on public interest issues puts into question whether Phase 2 will suitably address access and other issues.
*THIS STATEMENT MUST BE SUBMITTED BY THE END OF FRIDAY. Please make any comments with utmost urgency.*
Maureen tells me that she will issue a VERY SHORT Consensus Call tomorrow, to complete prior to the submission deadline.
WORD and PDF formats are attached.
Alan _______________________________________________ CPWG mailing list CPWG@icann.org https://mm.icann.org/mailman/listinfo/cpwg _______________________________________________ registration-issues-wg mailing list registration-issues-wg@atlarge-lists.icann.org https://mm.icann.org/mailman/listinfo/registration-issues-wg
participants (7)
-
Alan Greenberg -
Alberto Soto -
Bartlett Morgan -
Bastiaan Goslings -
Holly Raiche -
Kan Kaili -
Seun Ojedeji