Hi all again, Because there is not much time I include herein my comment so that you can all comment on. Thank you in advance. I have also sent it to Alan as being a member of the team he is certainly the expert on this. Thanks The ALAC welcomes the report of the registration directory service (RDS) second review team and takes this opportunity to provide its comments on the report herein. The ALAC fully supports the recommendations in relation to objective one with regard to the recommendations of the first RDS review team and we particularly note the importance of recommendation R5.1 addressing the data accuracy. Principle 5(1)d of the GDPR particularly requires that all reasonable steps are taken to ensure the personal data is not incorrect or misleading as to any matter of fact. Depending on the purpose of use of the data, it should be kept updated. In addition, all challenges to the accuracy of the data should be taken into consideration. To comply with GDPR, serve the purpose of collection and give the data subjects their rights; implementation of this high priority recommendation is required. We also note the importance of this recommendation in supporting the entities that work to protect the Internet end users. With regard to recommendation R12.1 we would like to highlight the importance of the translation of the registration data. However, we understand that reviewing the effectiveness of the recommendations of the first review team in this regard is currently not possible and that such an evaluation will only be possible after the adoption of the new Registration Data Access Protocol (RDAP). The ALAC regards some of the findings with regard to objective three in relation to the law enforcement needs as very important. Where 60% of the respondents to a survey to identify possible alternatives to the RDS lookups that would fulfill the same investigative need, indicated that they do not have any other tool in this regard. In addition, 89% of the respondents deemed RDS as very important. The ALAC welcomes the recommendation of the team and supports surveys and information gathering. In addition, we note to the importance of the surveys conducted by the WHOIS2 review team to the EPDP team working on gTLD registration data policy development. In addressing objective four, consumer trust the ALAC finds the definition of consumer trust in relation to the RDS provided by the WHOIS1 review final report which says “consumer trust can be narrowly construed to mean the level of trust users have in available WHOIS data; or more broadly as the level of trust consumers have in Internet information and transactions in general” as a very important guide when looking at the benefits of the RDS to users. The report mentions that although users do not directly use the system nevertheless the data stored does indirectly significantly impact users. The ALAC would like to emphasis on the findings of the review team and its importance to the Internet users. Finally, in light of the Temp. Spec and the new RDS policy being developed to comply with the GDPR the ALAC acknowledges the challenges that might have faced the review team in the development of the report. Nevertheless, we find the report including very useful information that should be used to guide the development of relevant policies. The ALAC appreciates the team’s effort and supports the provided recommendations Best Hadia ________________________________ From: Hadia Abdelsalam Mokhtar EL miniawi Sent: 21 November 2019 18:28 To: CPWG Cc: Evin Erdogdu Subject: RE: [community] ALAC > Action items: 2019-11-20 Consolidated Policy Working Group Call Hi all, I have put a draft comment on RDS WHOIS2 review. Kindly take a look and put your comments. Thanks Hadia From: Evin Erdogdu (Confluence) [mailto:no-reply@icann.org] Sent: Thursday, November 21, 2019 1:10 AM To: Hadia Abdelsalam Mokhtar EL miniawi Subject: [community] ALAC > Action items: 2019-11-20 Consolidated Policy Working Group Call There's 2 new edits on this page [page icon]<https://community.icann.org/display/atlarge/Action+items%3A+2019-11-20+Conso...> Action items: 2019-11-20 Consolidated Policy Working Group Call<https://community.icann.org/display/atlarge/Action+items%3A+2019-11-20+Conso...> [cid:image002.png@01D5A099.3BEDD360] Evin Erdogdu edited this page Here's what changed: [?] DoH - Microsoft implementation to be on agenda next week. Guest speaker to be asked (from SSAC) - @Olivier Crepin-Leblond</display/~olivier.crepin-leblond>, @Jonathan Zuck</display/~jonathan.zuck>, @Evin Erdogdu</display/~evin.erdogdu>. Reference Microsoft announcement re: DOH over https : https://techcommunity.microsoft.com/t5/Networking-Blog/Windows-will-improve-... and CircleID post: http://www.circleid.com/posts/20191118_microsoft_announces_plans_to_adopt_do... [?] @Claudia Ruiz</display/~claudia.ruiz> / @Yesim Nazlar</display/~yesim.nazlar> Single Issue called to be scheduled the week of 2 December (TBD) on ISOC selling PIR. Goal to issue ALAC advice during the 30 day ICANN review process. [?] Elements of SSR2 recommendations to be incorporated into ALAC Advice on DNS Abuse. @Evin Erdogdu</display/~evin.erdogdu>/ @Jonathan Zuck</display/~jonathan.zuck>. Reference The SSR2 wiki: SSR2 Review</pages/viewpage.action?pageId=58740224> [?] @Justine Chew</display/~justine.chew> volunteered to review / be initial penholder of Implementation Plan for the GNSO Consensus Policy Relating to the Protection of Certain Red Cross Names<https://community.icann.org/display/alacpolicydev/At-Large+Workspace%3A+Impl...>. [?] @Jonathan Zuck</display/~jonathan.zuck> to finalize ALAC Advice on DNS abuse for next CPWG call (27 November), with slide presentation. [?] @Evin Erdogdu</display/~evin.erdogdu> to circulate recording of At-Large DNS Abuse session at ICANN66 to the CPWG mailing list. [?] @Jonathan Zuck</display/~jonathan.zuck> to coordinate with staff and ALAC leadership on distributing GeoNames survey to ALSes / At-Large channels. [?] @Evin Erdogdu</display/~evin.erdogdu> to mark Proposed IANA SLAs for ccTLD Creation and Transfer<https://community.icann.org/display/alacpolicydev/At-Large+Workspace%3A++Pro...> as No Statement. [?] @Evin Erdogdu</display/~evin.erdogdu> to request extension for Invitation to Provide Input for PDP 3.0 Implementation<https://community.icann.org/x/Y4kzBw> on behalf of ALAC. [?] @Hadia Elminiawi</display/~hadia.elminiawi> to work with @Evin Erdogdu</display/~evin.erdogdu> on drafting and submitting the ALAC statement on Registration Directory Service (RDS-WHOIS2) Review Team Final Report<https://community.icann.org/display/alacpolicydev/At-Large+Workspace%3A+Regi...>. [?] @Holly Raiche</display/~holly.raiche> volunteered to provide input on Invitation to Provide Input for PDP 3.0 Implementation<https://community.icann.org/display/alacpolicydev/At-Large+Workspace%3A+Invi...>. [?] @Claudia Ruiz</display/~claudia.ruiz> to schedule next CPWG on Weds 27 Nov at either 13 or 19 UTC. 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