Implementing WHOIS Requirements per RAA 2013
See the details here: http://www.icann.org/en/news/announcements/announcement-31jul13-en.htm -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
Hi Carlton It doesn't look like they are looking for any input from anyone - except registrars. Am I right? And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback? Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement-31jul13-en.htm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs. Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process. Best, -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement-31jul13-en.htm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Hi Carlton Thanks for this. My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone. I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC. For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC. I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying. Just please keep us informed of ongoing discussions. Thanks Holly On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement-31jul13-en.htm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Hi Holly: It would be well-intentioned for the ALAC to put its views on record. And yes, although I do not represent the ALAC in this framework, I do indeed share my impression of the substantive discussions with my EWG colleagues. I have from inception facilitated the discussions surrounding access to registrant data in the EWG. And to be frank, the views surrounding that I have held and espoused in the ALAC have evolved a tad in this framework. You could reasonably say my views have evolved in pursuit of consensus. All this aside and while I am well-versed in wearing multiple hats in my business, I feel it is appropriate that I recuse myself from participating in developing the specific ALAC response to the EWG report. Best, -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Sun, Aug 4, 2013 at 4:07 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement-31jul13-en.htm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Hi Carlton You are the last person who should leave the debate! Please DO NOT recuse yourself. You have been involved in the discussions and can guide the rest of us. The value of you being on the EWG is to help the rest of us. If you don't want to put your name to something, fine. But we need your brains and input - please. Holly On 05/08/2013, at 8:31 AM, Carlton Samuels wrote:
Hi Holly: It would be well-intentioned for the ALAC to put its views on record. And yes, although I do not represent the ALAC in this framework, I do indeed share my impression of the substantive discussions with my EWG colleagues.
I have from inception facilitated the discussions surrounding access to registrant data in the EWG. And to be frank, the views surrounding that I have held and espoused in the ALAC have evolved a tad in this framework. You could reasonably say my views have evolved in pursuit of consensus.
All this aside and while I am well-versed in wearing multiple hats in my business, I feel it is appropriate that I recuse myself from participating in developing the specific ALAC response to the EWG report.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Sun, Aug 4, 2013 at 4:07 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement-31jul13-en.htm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h tm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Thank you Karl and Roberto for your comments Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least. Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data. Holly On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h tm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R. PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h tm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Great comments Roberto. There are other parts of this puzzle that are technical but what we should be doing is setting some high level principles - and looking to our technical experts who may have for better ways to solve some of the issues Holly On 05/08/2013, at 11:25 AM, Roberto Gaetano wrote:
Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R.
PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
> See the details here: > http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h > tm > > -Carlton > > ============================== > Carlton A Samuels > Mobile: 876-818-1799 > *Strategy, Planning, Governance, Assessment & Turnaround* > ============================= > _______________________________________________ > At-Large mailing list > At-Large@atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/at-large > > At-Large Official Site: http://atlarge.icann.org
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Dear Holly, I support having an ALAC statement on the EWG proposal where we express general support and focus on principles and policy parameters that implementation should meet as per Roberto's suggestion. On the complexity of the database (location/s and jurisdiction, decentralization and data segmentation method plus access rights issues), let us say that we would like to see options that meet the criteria for end user protection (and these criteria can be outlined). Alan indicated in another email thread that much imagination is needed to figure this out. Well, let's call for imaginative options for the community's consideration that hit the mark (our mark). I am sure there are brilliant minds out there who together can come up with great ideas. The submission of the principles that need to be met via the statement need not wait for the solutions that still need to be developed. Best regards, Rinalia Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R. PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h tm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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All the points raised have been in discussion in the EWG. Some of the ideas here about treating the access issues have also been introduced. The core idea is that use cases are consistent with safeguarding the stability and security and retention of user confidence in the DNS. Thus any nextgen RDS must, at minumum, meet these obligations even as it addresses the existing vexed disabilities. That said and for clarification, the EWG is generally wary of adopting a coloration that could be construed as promoting implementation schemes or usurping those responsibilities. Rather, its objective is to clearly expound the principles that must undergird the nextgen registration data services and deliver those to the PDP process via the ICANN Board. We are also very keen to ensure clarity of our thinking is communicated, especially for the more controversial issues. So after much argument, a very strong consensus was adopted. We collectively accepted that in instances where details that could reasonably be inferred as design criteria are necessary to full understanding of a proposal, the clarity objective supercede all others. The rationale for an aggregated gTLD registration database rests on five (5) compelling principles: 1. That registration data elements meet defined accuracy standards across all domains 2. That there must be universal access to a small defined core set of data elements for each and every registration 3. That a data privacy regime of sufficient malleability be adopted for implementation in keeping with existing legal privacy frameworks across all domains 4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated need across all domains 5. An authoritative third party compliance mechanism is enabled to ensure 1 - 4 Now, are there other principles that should be embraced? Maybe. Let us be clear, these are open for revision and extension. Obviously, agency is critical to implementation. I am pleased to see recognized here the distinction between the logical and physical database and, even the likely implementation scenarios surrounding, placement being just one. Yes, cross-border jurisdictional issues and asymmetric privacy regimes in respect of multi-modal access will be impactful and are also critical considerations. Working groups have been raised to 'deep dive' these matters and I'm co-opted to both. We meet in DC Aug 27-30 to advance the work. I am also co-opted -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Sun, Aug 4, 2013 at 8:25 PM, Roberto Gaetano <roberto_gaetano@hotmail.com
wrote:
Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R.
PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
> See the details here: > http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h > tm > > -Carlton > > ============================== > Carlton A Samuels > Mobile: 876-818-1799 > *Strategy, Planning, Governance, Assessment & Turnaround* > ============================= > _______________________________________________ > At-Large mailing list > At-Large@atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/at-large > > At-Large Official Site: http://atlarge.icann.org
_______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Dear All: I made a significant error in Principle #4. The word 'need' should be replaced with 'purpose'. The Principle then becomes: 4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated *purpose* across all domains Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Mon, Aug 5, 2013 at 4:57 PM, Carlton Samuels <carlton.samuels@gmail.com>wrote:
All the points raised have been in discussion in the EWG. Some of the ideas here about treating the access issues have also been introduced. The core idea is that use cases are consistent with safeguarding the stability and security and retention of user confidence in the DNS. Thus any nextgen RDS must, at minumum, meet these obligations even as it addresses the existing vexed disabilities.
That said and for clarification, the EWG is generally wary of adopting a coloration that could be construed as promoting implementation schemes or usurping those responsibilities. Rather, its objective is to clearly expound the principles that must undergird the nextgen registration data services and deliver those to the PDP process via the ICANN Board. We are also very keen to ensure clarity of our thinking is communicated, especially for the more controversial issues. So after much argument, a very strong consensus was adopted. We collectively accepted that in instances where details that could reasonably be inferred as design criteria are necessary to full understanding of a proposal, the clarity objective supercede all others.
The rationale for an aggregated gTLD registration database rests on five (5) compelling principles: 1. That registration data elements meet defined accuracy standards across all domains 2. That there must be universal access to a small defined core set of data elements for each and every registration 3. That a data privacy regime of sufficient malleability be adopted for implementation in keeping with existing legal privacy frameworks across all domains 4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated need across all domains 5. An authoritative third party compliance mechanism is enabled to ensure 1 - 4
Now, are there other principles that should be embraced? Maybe. Let us be clear, these are open for revision and extension.
Obviously, agency is critical to implementation. I am pleased to see recognized here the distinction between the logical and physical database and, even the likely implementation scenarios surrounding, placement being just one. Yes, cross-border jurisdictional issues and asymmetric privacy regimes in respect of multi-modal access will be impactful and are also critical considerations. Working groups have been raised to 'deep dive' these matters and I'm co-opted to both.
We meet in DC Aug 27-30 to advance the work. I am also co-opted
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Sun, Aug 4, 2013 at 8:25 PM, Roberto Gaetano < roberto_gaetano@hotmail.com> wrote:
Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R.
PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
> Hi Carlton > > It doesn't look like they are looking for any input from anyone - > except registrars. Am I right? > > And a related question - is ALAC making a statement of the EWG > Initial Report. I don't see anything on the policy page, but my > understanding was that they were looking for feedback? > > Holly > On 02/08/2013, at 2:50 AM, Carlton Samuels wrote: > >> See the details here: >> http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h >> tm >> >> -Carlton >> >> ============================== >> Carlton A Samuels >> Mobile: 876-818-1799 >> *Strategy, Planning, Governance, Assessment & Turnaround* >> ============================= >> _______________________________________________ >> At-Large mailing list >> At-Large@atlarge-lists.icann.org >> https://atlarge-lists.icann.org/mailman/listinfo/at-large >> >> At-Large Official Site: http://atlarge.icann.org > > _______________________________________________ > At-Large mailing list > At-Large@atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/at-large > > At-Large Official Site: http://atlarge.icann.org > _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Carlton, Forgive me as someone who is jumping in "blind" to this thread. Clearly a lot of work and deep thought has gone into these ideas. However I don't understand what is meant by the phrase 'adjudicated *purpose* across all domains'. As a general nod I would have thought that defining 'purpose' or 'purposes' is critical as otherwise mission creep is built in and any principles if not set in legal stone globally that is in each and every significant jurisdiction with a responsible entity over a gtld registry won't be dependable. Are such purposes clearly defined or acknowledged or likely to be agreed? best Christian Carlton Samuels wrote:
Dear All: I made a significant error in Principle #4. The word 'need' should be replaced with 'purpose'. The Principle then becomes:
4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated *purpose* across all domains
Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Mon, Aug 5, 2013 at 4:57 PM, Carlton Samuels <carlton.samuels@gmail.com>wrote:
All the points raised have been in discussion in the EWG. Some of the ideas here about treating the access issues have also been introduced. The core idea is that use cases are consistent with safeguarding the stability and security and retention of user confidence in the DNS. Thus any nextgen RDS must, at minumum, meet these obligations even as it addresses the existing vexed disabilities.
That said and for clarification, the EWG is generally wary of adopting a coloration that could be construed as promoting implementation schemes or usurping those responsibilities. Rather, its objective is to clearly expound the principles that must undergird the nextgen registration data services and deliver those to the PDP process via the ICANN Board. We are also very keen to ensure clarity of our thinking is communicated, especially for the more controversial issues. So after much argument, a very strong consensus was adopted. We collectively accepted that in instances where details that could reasonably be inferred as design criteria are necessary to full understanding of a proposal, the clarity objective supercede all others.
The rationale for an aggregated gTLD registration database rests on five (5) compelling principles: 1. That registration data elements meet defined accuracy standards across all domains 2. That there must be universal access to a small defined core set of data elements for each and every registration 3. That a data privacy regime of sufficient malleability be adopted for implementation in keeping with existing legal privacy frameworks across all domains 4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated need across all domains 5. An authoritative third party compliance mechanism is enabled to ensure 1 - 4
Now, are there other principles that should be embraced? Maybe. Let us be clear, these are open for revision and extension.
Obviously, agency is critical to implementation. I am pleased to see recognized here the distinction between the logical and physical database and, even the likely implementation scenarios surrounding, placement being just one. Yes, cross-border jurisdictional issues and asymmetric privacy regimes in respect of multi-modal access will be impactful and are also critical considerations. Working groups have been raised to 'deep dive' these matters and I'm co-opted to both.
We meet in DC Aug 27-30 to advance the work. I am also co-opted
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Sun, Aug 4, 2013 at 8:25 PM, Roberto Gaetano < roberto_gaetano@hotmail.com> wrote:
Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R.
PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
> Hi Holly: > I should think not; this was an advisory and in any event, we have > spoken often and endorsed the collection of the entire dataset as > defined in the specs. > > Regarding the EWG work, there was talk of placing an official ALAC > response to invitation for comments. Since I'm a member of the EWG, > speaking aloud to myself might very well be considered just desserts > in some quarters and as such not to be encouraged. So I will exempt myself from that process. > Best, > -Carlton > > > ============================== > Carlton A Samuels > Mobile: 876-818-1799 > *Strategy, Planning, Governance, Assessment & Turnaround* > ============================= > > > On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote: >> Hi Carlton >> >> It doesn't look like they are looking for any input from anyone - >> except registrars. Am I right? >> >> And a related question - is ALAC making a statement of the EWG >> Initial Report. I don't see anything on the policy page, but my >> understanding was that they were looking for feedback? >> >> Holly >> On 02/08/2013, at 2:50 AM, Carlton Samuels wrote: >> >>> See the details here: >>> http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h >>> tm >>> >>> -Carlton >>> >>> ============================== >>> Carlton A Samuels >>> Mobile: 876-818-1799 >>> *Strategy, Planning, Governance, Assessment & Turnaround* >>> ============================= >>> _______________________________________________ >>> At-Large mailing list >>> At-Large@atlarge-lists.icann.org >>> https://atlarge-lists.icann.org/mailman/listinfo/at-large >>> >>> At-Large Official Site: http://atlarge.icann.org >> _______________________________________________ >> At-Large mailing list >> At-Large@atlarge-lists.icann.org >> https://atlarge-lists.icann.org/mailman/listinfo/at-large >> >> At-Large Official Site: http://atlarge.icann.org >> > _______________________________________________ > At-Large mailing list > At-Large@atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/at-large > > At-Large Official Site: http://atlarge.icann.org _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Hi Christian: Other than for a fringe element, it is generally accepted that registration data is collected and necessarily so. The contentions surround what is collected, purpose of collection, access to what is collected and use of that data. The EWG focused on these areas by exploring what we call use cases since the contentious elements converged here. Facilitating the access issues in particular meant we focused on the dataset collected and fitness to purpose and who should have access and for what purpose, all in context of maintaining a healthy DNS. In this same context, some purposes of use were deemed to be 'good', others 'bad'. At least in our judgment. And all this is before 'on the fly re-purposing' is contemplated. The overall objective of a new arrangement then is a system that is maximized to service the 'good' purposes and drastically reduce, if not eliminate, the 'bad' ones. At least in our judgment. The account of 'good' purposes is the judgment of a small group. So if our premise is to go forward and guide solution, we would seek to have a wider judgment on these purposes delivered; hence the 'adjudication', meaning acknowledged and agreed. The extension principle is assumed here so other judgments are welcome. Best, -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Thu, Aug 8, 2013 at 2:58 AM, Christian de Larrinaga <cdel@firsthand.net>wrote:
Carlton,
Forgive me as someone who is jumping in "blind" to this thread. Clearly a lot of work and deep thought has gone into these ideas.
However I don't understand what is meant by the phrase 'adjudicated *purpose* across all domains'.
As a general nod I would have thought that defining 'purpose' or 'purposes' is critical as otherwise mission creep is built in and any principles if not set in legal stone globally that is in each and every significant jurisdiction with a responsible entity over a gtld registry won't be dependable.
Are such purposes clearly defined or acknowledged or likely to be agreed?
best
Christian
Carlton Samuels wrote:
Dear All: I made a significant error in Principle #4. The word 'need' should be replaced with 'purpose'. The Principle then becomes:
4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated *purpose* across all domains
Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Mon, Aug 5, 2013 at 4:57 PM, Carlton Samuels <carlton.samuels@gmail.com>wrote:
All the points raised have been in discussion in the EWG. Some of the ideas here about treating the access issues have also been introduced. The core idea is that use cases are consistent with safeguarding the stability and security and retention of user confidence in the DNS. Thus any nextgen RDS must, at minumum, meet these obligations even as it addresses the existing vexed disabilities.
That said and for clarification, the EWG is generally wary of adopting a coloration that could be construed as promoting implementation schemes or usurping those responsibilities. Rather, its objective is to clearly expound the principles that must undergird the nextgen registration data services and deliver those to the PDP process via the ICANN Board. We are also very keen to ensure clarity of our thinking is communicated, especially for the more controversial issues. So after much argument, a very strong consensus was adopted. We collectively accepted that in instances where details that could reasonably be inferred as design criteria are necessary to full understanding of a proposal, the clarity objective supercede all others.
The rationale for an aggregated gTLD registration database rests on five (5) compelling principles: 1. That registration data elements meet defined accuracy standards across all domains 2. That there must be universal access to a small defined core set of data elements for each and every registration 3. That a data privacy regime of sufficient malleability be adopted for implementation in keeping with existing legal privacy frameworks across all domains 4. That access to all other data elements beyond the core set available for universal access be restricted and only allowed based on adjudicated need across all domains 5. An authoritative third party compliance mechanism is enabled to ensure 1 - 4
Now, are there other principles that should be embraced? Maybe. Let us be clear, these are open for revision and extension.
Obviously, agency is critical to implementation. I am pleased to see recognized here the distinction between the logical and physical database and, even the likely implementation scenarios surrounding, placement being just one. Yes, cross-border jurisdictional issues and asymmetric privacy regimes in respect of multi-modal access will be impactful and are also critical considerations. Working groups have been raised to 'deep dive' these matters and I'm co-opted to both.
We meet in DC Aug 27-30 to advance the work. I am also co-opted
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Sun, Aug 4, 2013 at 8:25 PM, Roberto Gaetano < roberto_gaetano@hotmail.com> wrote:
Holly, This is where the ALAC advice can be different from the WG members' advice. While the WG might be struggling with implementation issues, ALAC, being an advisory body on *policy* and not on *implementation*, shall concentrate on the requirements for the database. In short, we can require that the data shall be retrieved only via the interface. Or set benchmark criteria. I don't believe we can get into geopolitics, and name countries that should not "own" the database. As for the technical solution, whether the database is located in a country that has specific privacy rights prevailing over judge orders, or whether the database is split in parts that are distributed in different countries so that no one country can have the full information on any registrant, that is beyond our mandate. Long story short, I agree with your approach. Cheers, R.
PS: At some point in time we need to deal also with the fact that EU laws prohibit the transfer of personal data outside Europe without the consent of the registrant
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: lunedì 5 agosto 2013 02:37 A: At-Large Worldwide Oggetto: Re: [At-Large] R: Implementing WHOIS Requirements per RAA 2013
Thank you Karl and Roberto for your comments
Roberto, the location of the ARDS is absolutely front and centre as an issue. Some of the immediate comments I heard was to insist the database NOT be located in the US (followed by a long list of other undesirable locations). I would imagine places like Geneva or Brussels (or Finland) would be more easily accepted. But I think the better solution is to describe the venue in terms of strict and enforceable (and enforced) privacy laws. - set benchmark criteria at the least.
Other issues that were discussed on the day included enforcement - by whom (ICANN's compliance department has not covered itself with glory on this one), and defining who can have access to what data.
Holly
On 05/08/2013, at 10:13 AM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
> -----Messaggio originale----- > Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- > bounces@atlarge-lists.icann.org] Per conto di Holly Raiche > Inviato: domenica 4 agosto 2013 23:08 > A: At-Large Worldwide > Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013 > > Hi Carlton > > Thanks for this. > > My one concern about ALAC not developing its own input is that, at > the GNSO meeting Evan and I attended (and where Michele presented), > he specifically asked, indeed pleaded for feedback from everyone. > > I am sure that you will be taking the views that we have discussed to > the EWG. But I think my question is whether it would not make sense > to have official ALAC input on this particular proposal. It is > different enough so that > ALAC statements in the past are not applicable to this proposal. And, as the > discussion between Garth, you, Evan, Rinalia and I showed in Durban, > there are different views on the proposal within ALAC. > > For example, should we give the many reforms to the RAA a chance to > work first? Should compliance be left to the compliance area within > ICANN or to this new proposed ARDS? And what happens to the RAA > requirements on verification if the ARDS takes over that function, as > well as being the gatekeeper for access to data. It is a new road > with much to commend it but, > as our discussions showed, some real reservations, and some real > differences even within ALAC. > > I trust you to reflect those differences, but worry that you don't > have official > ALAC statements to support what you are saying. > > Just please keep us informed of ongoing discussions. > > Thanks > > Holly > > > > > On 05/08/2013, at 6:23 AM, Carlton Samuels wrote: > >> Hi Holly: >> I should think not; this was an advisory and in any event, we have >> spoken often and endorsed the collection of the entire dataset as >> defined in the specs. >> >> Regarding the EWG work, there was talk of placing an official ALAC >> response to invitation for comments. Since I'm a member of the EWG, >> speaking aloud to myself might very well be considered just desserts >> in some quarters and as such not to be encouraged. So I will exempt myself > from that process. >> Best, >> -Carlton >> >> >> ============================== >> Carlton A Samuels >> Mobile: 876-818-1799 >> *Strategy, Planning, Governance, Assessment & Turnaround* >> ============================= >> >> >> On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche > <h.raiche@internode.on.net>wrote: >>> Hi Carlton >>> >>> It doesn't look like they are looking for any input from anyone - >>> except registrars. Am I right? >>> >>> And a related question - is ALAC making a statement of the EWG >>> Initial Report. I don't see anything on the policy page, but my >>> understanding was that they were looking for feedback? >>> >>> Holly >>> On 02/08/2013, at 2:50 AM, Carlton Samuels wrote: >>> >>>> See the details here: >>>> http://www.icann.org/en/news/announcements/announcement- > 31jul13-en.h >>>> tm >>>> >>>> -Carlton >>>> >>>> ============================== >>>> Carlton A Samuels >>>> Mobile: 876-818-1799 >>>> *Strategy, Planning, Governance, Assessment & Turnaround* >>>> ============================= >>>> _______________________________________________ >>>> At-Large mailing list >>>> At-Large@atlarge-lists.icann.org >>>> https://atlarge-lists.icann.org/mailman/listinfo/at-large >>>> >>>> At-Large Official Site: http://atlarge.icann.org >>> _______________________________________________ >>> At-Large mailing list >>> At-Large@atlarge-lists.icann.org >>> https://atlarge-lists.icann.org/mailman/listinfo/at-large >>> >>> At-Large Official Site: http://atlarge.icann.org >>> >> _______________________________________________ >> At-Large mailing list >> At-Large@atlarge-lists.icann.org >> https://atlarge-lists.icann.org/mailman/listinfo/at-large >> >> At-Large Official Site: http://atlarge.icann.org > _______________________________________________ > At-Large mailing list > At-Large@atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/at-large > > At-Large Official Site: http://atlarge.icann.org _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
At-Large Official Site: http://atlarge.icann.org
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This is certainly one of the more questionable aspects of the EWG proposal. Two design issues come to mind that both make it better and worse. First, because there is one logical ARDS database does not necessarily mean there is a single physical database. If fact it could be segmented in a number of ways. The data for different registries could be stored in different venues. Or, perhaps more intriguingly, the data itself could be scatters over several venues so that no single country could reconstruct the entire database. Of course several acting together could. In either case, the location of the portal which can re-create the entire ARDS database would be subject to its national laws. Secondly, good design dictates that just as there are multiple root servers (and multiple incarnations of each), presumably the logical and physical ARDS database would nened to be replicated to ensure that there is not a single point of failure. All of this makes it very difficult to imagine an implementation that is both robust and with guaranteed privacy. But perhaps I lack the proper imagination. Alan At 04/08/2013 08:13 PM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h tm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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Hi Alan No, you don't lack imagination. This is exactly the debate we need to be having. (and it is what Michele rightly believes is necessary). But first, we need to say the proposal is worth pursuing and then listing what our concerns are. Holly On 05/08/2013, at 11:31 AM, Alan Greenberg wrote:
This is certainly one of the more questionable aspects of the EWG proposal. Two design issues come to mind that both make it better and worse. First, because there is one logical ARDS database does not necessarily mean there is a single physical database. If fact it could be segmented in a number of ways. The data for different registries could be stored in different venues. Or, perhaps more intriguingly, the data itself could be scatters over several venues so that no single country could reconstruct the entire database. Of course several acting together could. In either case, the location of the portal which can re-create the entire ARDS database would be subject to its national laws.
Secondly, good design dictates that just as there are multiple root servers (and multiple incarnations of each), presumably the logical and physical ARDS database would nened to be replicated to ensure that there is not a single point of failure.
All of this makes it very difficult to imagine an implementation that is both robust and with guaranteed privacy.
But perhaps I lack the proper imagination.
Alan
At 04/08/2013 08:13 PM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
See the details here: http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h tm
-Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* ============================= _______________________________________________ At-Large mailing list At-Large@atlarge-lists.icann.org https://atlarge-lists.icann.org/mailman/listinfo/at-large
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To all women in this list As in last two years since we became part of the ICANN Agenda, we will have our DNS WOMEN BREAKFAST, inviting all professional women attending ICANN meeting. If you are going to ICANN meeting and/or have another friend who you know will attend, please spread the word. Our region needs to have at least the 90 women in the breakfast as other regions have done!!!! Kisses to all and hope to see you there! Vanda Scartezini Polo Consultores Associados Av. Paulista 1159, cj 1004 01311-200- Sao Paulo, SP, Brazil Land Line: +55 11 3266.6253 Mobile: + 55 11 98181.1464 On 04/08/13 23:39, "Holly Raiche" <h.raiche@internode.on.net> wrote:
Hi Alan
No, you don't lack imagination. This is exactly the debate we need to be having. (and it is what Michele rightly believes is necessary). But first, we need to say the proposal is worth pursuing and then listing what our concerns are.
Holly On 05/08/2013, at 11:31 AM, Alan Greenberg wrote:
This is certainly one of the more questionable aspects of the EWG proposal. Two design issues come to mind that both make it better and worse. First, because there is one logical ARDS database does not necessarily mean there is a single physical database. If fact it could be segmented in a number of ways. The data for different registries could be stored in different venues. Or, perhaps more intriguingly, the data itself could be scatters over several venues so that no single country could reconstruct the entire database. Of course several acting together could. In either case, the location of the portal which can re-create the entire ARDS database would be subject to its national laws.
Secondly, good design dictates that just as there are multiple root servers (and multiple incarnations of each), presumably the logical and physical ARDS database would nened to be replicated to ensure that there is not a single point of failure.
All of this makes it very difficult to imagine an implementation that is both robust and with guaranteed privacy.
But perhaps I lack the proper imagination.
Alan
At 04/08/2013 08:13 PM, Roberto Gaetano wrote:
I can provide one point for thoughts, that ALAC might think to include in the feedback. During the presentation, and in the text of the report, there is a description of how to design access to data in a way that it will be dependent on the rights the accessing entity has. However, there is one entity that might gain full access to all data, and this is the government of the country where the database will be physically located. I had a chat with Michele on this, and he assured me that this is one point that came already out, and will be discussed to find an acceptable solution. I have no clue about the dynamics of the WG, I am sure, knowing Carlton, that our points have been expressed loudly, but maybe a little help from an official ALAC statement can help. Let's put it this way: other constituencies and stakeholder groups will not be shy in making statements that will push further their opinion and needs, beyond what was the acceptable consensus of the WG: why should ALAC avoid providing feedback? Michele is absolutely right when he calls for further input, he knows some will speak up anyway, it is fair if all do. Elaborating on the localization of the database, that we know is an issue, is there something we can suggest? We do not need to provide the technical solution, but can we spell out the requirements for making sure that no specific entity will be more equal than others? Cheers, Roberto
-----Messaggio originale----- Da: at-large-bounces@atlarge-lists.icann.org [mailto:at-large- bounces@atlarge-lists.icann.org] Per conto di Holly Raiche Inviato: domenica 4 agosto 2013 23:08 A: At-Large Worldwide Oggetto: Re: [At-Large] Implementing WHOIS Requirements per RAA 2013
Hi Carlton
Thanks for this.
My one concern about ALAC not developing its own input is that, at the GNSO meeting Evan and I attended (and where Michele presented), he specifically asked, indeed pleaded for feedback from everyone.
I am sure that you will be taking the views that we have discussed to the EWG. But I think my question is whether it would not make sense to have official ALAC input on this particular proposal. It is different enough so that ALAC statements in the past are not applicable to this proposal. And, as the discussion between Garth, you, Evan, Rinalia and I showed in Durban, there are different views on the proposal within ALAC.
For example, should we give the many reforms to the RAA a chance to work first? Should compliance be left to the compliance area within ICANN or to this new proposed ARDS? And what happens to the RAA requirements on verification if the ARDS takes over that function, as well as being the gatekeeper for access to data. It is a new road with much to commend it but, as our discussions showed, some real reservations, and some real differences even within ALAC.
I trust you to reflect those differences, but worry that you don't have official ALAC statements to support what you are saying.
Just please keep us informed of ongoing discussions.
Thanks
Holly
On 05/08/2013, at 6:23 AM, Carlton Samuels wrote:
Hi Holly: I should think not; this was an advisory and in any event, we have spoken often and endorsed the collection of the entire dataset as defined in the specs.
Regarding the EWG work, there was talk of placing an official ALAC response to invitation for comments. Since I'm a member of the EWG, speaking aloud to myself might very well be considered just desserts in some quarters and as such not to be encouraged. So I will exempt myself from that process.
Best, -Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 *Strategy, Planning, Governance, Assessment & Turnaround* =============================
On Thu, Aug 1, 2013 at 10:46 PM, Holly Raiche <h.raiche@internode.on.net>wrote:
Hi Carlton
It doesn't look like they are looking for any input from anyone - except registrars. Am I right?
And a related question - is ALAC making a statement of the EWG Initial Report. I don't see anything on the policy page, but my understanding was that they were looking for feedback?
Holly On 02/08/2013, at 2:50 AM, Carlton Samuels wrote:
> See the details here: > http://www.icann.org/en/news/announcements/announcement- 31jul13-en.h > tm > > -Carlton > > ============================== > Carlton A Samuels > Mobile: 876-818-1799 > *Strategy, Planning, Governance, Assessment & Turnaround* > ============================= > _______________________________________________ > At-Large mailing list > At-Large@atlarge-lists.icann.org > https://atlarge-lists.icann.org/mailman/listinfo/at-large > > At-Large Official Site: http://atlarge.icann.org
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participants (7)
-
Alan Greenberg -
Carlton Samuels -
Christian de Larrinaga -
Holly Raiche -
Rinalia Abdul Rahim -
Roberto Gaetano -
Vanda Scartezini