Dear Tijani,
the Statement is indeed long, that's why there should be a half page
executive summary at the beginning, like there used to be in the
past. This one really needs a summary.
Kindest regards,
Olivier
On 20/09/2018 12:54, Tijani BEN JEMAA
wrote:
Dear all,
I didn’t want to
comment before I read the proposed UAM, Greg proposed
statement and Christopher comments.
I would like first to
thank Greg for the comprehensive statement and the analysis he
made. A huge work even if I find it not a statement of ALAC to
advise the board or to comment on the ICANN org proposal
during a public comment period, but a too long advocating text
that can be useful for internal discussion.
When we make such
long document, there will likely be almost none to read it. I
think a more focused and direct to the point statement would
be much more efficient.
To
the content, I have to agree with Christopher remarks. I also
have reservation on registry operators to be required
to provide access. For the record, Verisign has only thin
whois of dot com, so, registries don’t have always all
collected data. And why we need to distribute the
responsibility of giving access? I think Registrars only
should be required to give access.
-----------------------------------------------------------------------------
Tijani BEN
JEMAA
Executive
Director
Mediterranean
Federation of Internet Associations (FMAI)
Phone: +216
98 330 114
+216 52 385
114
-----------------------------------------------------------------------------
Hello CW,
Am
sorry I caused some confusion, it's been clarified that
the draft
statement
on this subject is currently not at it's voting stage so
there
will
indeed be revisions and I expect that your comments will
be taken into
consideration.
Regards
Sent
from my mobile
Kindly
excuse brevity and typos
On
Tue, 18 Sep 2018, 16:29 mail@christopherwilkinson.eu CW, <
mail@christopherwilkinson.eu>
wrote:
Seun: What
should I do now? Several support my comments. None
support the
original text?
When is the next CPWG meeting?
C.
El 18 de septiembre de 2018 a las 15:38 Seun Ojedeji
<
seun.ojedeji@gmail.com>
escribió:
Hello Alan,
Wrong call, I think I may have mixed up the statements:
https://community.icann.org/x/CwA5BQ
Regards
Sent from my mobile
Kindly excuse brevity and typos
On Tue, 18 Sep 2018, 12:47 Seun Ojedeji,
<seun.ojedeji@gmail.com> wrote:
Dear Alan,
Considering that some are having concern about the
statement and since
ALAC members have voting rights to same, I will like to
request that the
current vote on the statement be extended or put on hold
in order to review
the statement accordingly.
Regards
Sent from my mobile
Kindly excuse brevity and typos
On Tue, 18 Sep 2018, 11:35 Marita Moll,
<mmoll@ca.inter.net> wrote:
I am supportive as well. Thanks for you remarks.
Marita
On 9/16/2018 10:51 PM, Roberto Gaetano wrote:
+1
Excellent remarks
R
On 16.09.2018, at 22:13, mail@christopherwilkinson.eu CW
<
mail@christopherwilkinson.eu> wrote:
Good evening:
Please find below and attached a few comments on the
proposed draft ALAC
statement UAM and related matters.
Regards
Christopher Wilkinson
--------------------------
*ALAC Draft statement on GDPR and UAM.*
*Comments from Christopher Wilkinson*
*General*
The draft paper brings forward some interesting
arguments and a useful
perspective on certain aspects of ICANN's provisional
UAM position. It is
not clear how these aspects relate to the on-going work
in the other
current ICANN fora, notably the EPDR.
Although this draft is rather long for the purpose that
it serves, it
helps to relate the eventual ALAC position to the ICANN
interim proposals.
Here it would be helpful for a start to show clearly
that the different
fonts and colours that are used carry distinct meanings.
Thus, it is only
the paragraphs that appear in *italics *that constitute
the proposed ALAC
statement. Correct?
At several junctures in the draft, the text reads rather
more like a
defense of the IPR interest in WHOIS as expounded by the
IPC constituency
rather than a draft ALAC statement on behalf of the At
Large community and
Internet users, world wide.
I do not share the implicit presumption that there is
some sort of
co-incidence between trademark rights and consumer
protection. Trademark
protection is primarily about maintaining prices for
branded products.
Insofar as the IPC wishes to make the case for an open
Whois, they are of
course free to do so, but I think that is not an
appropriate line for ALAC
to take.
*Third party access*
Specifically, the draft refers several times to access
to data by third
parties who would become 'accredited users'. Who are
they going to be? How
shall they be defined, world-wide? Who will accredit
them?
Thus, we have 'intellectual property lawyers' and
'accredited parties'
(p.2). Later, (p.3) we have 'a finite list of types of
third parties …
[which] should not be exhaustive … and needs to be
fairly limited'. Which
are suggested to be 'just examples'. There seems to be
some internal
contradiction here.
From a global perspective there is arguably a serious
problem of
definition and coherence among this terminology. Notably
in the event of
'global access' (p.5); so that a Registrar in country A,
would have to give
access to an 'accredited' third party from country B,
that the Registrar
may not know and may not trust.
*Eligibility*
In an ideal world one might give credence to the ability
of a multi
stakeholder process to deliver criteria for eligibility.
However, the fact
is that the ICANN multi stakeholder community is still
highly biassed
towards the interests of certain countries and certain
stakeholders. Most
governments, world-wide, are quite unlikely to accept
criteria and
identified Eligible User Groups as determined by the
ICANN multi
stakeholder community as it is currently constituted.
Particularly if the
process in question is designed to minimise the
information and influence
of the governments concerned. Furthermore, ALAC should
be careful what it
asks for; I would have serious doubts as to the capacity
or interest of our
At Large Structures (ALS) to reliably identify such
Eligible Users in all
their respective countries. It would of course be out of
the question for
stakeholders in third countries to identify their
preferred Eligible User
Groups in another jurisdiction.
The Framework's examples of Eligible User Groups is so
broad as to amount
almost to 'everyone concerned'. The effect of such a
wide scope would be to
dilute any possibility of effectively restricting access
to personal data,
and to considerably aggravate the possibility of
creating any such 'finite
list' of Eligible Users, as referred to above.
*Bulk Access*
It has been notorious for more than two decades that
bulk access to Whois
by agents and third parties has been one of the more
egregious breaches of
European data protection laws by ICANN.
Now it has got to stop.
Clearly, Whois data obtained legitimately must not be
forwarded to
unauthorised third parties (p.7) nor agglomerated to
create a shadow Whois.
However, these observations in the draft beg the
question as to how much
Whois data has already been accessed in bulk,
agglomerated and forwarded to
third parties? If so, has the data been deleted?
Furthermore, the very existence of this process in ICANN
is probably
creating an existential incentive to get and keep as
much Whois data as
possible before GDPR related restrictions are finally
introduced by ICANN.
Registries and Registrars should be instructed to
suspend all bulk access
forthwith, if they have not already done so.
* * * *
In conclusion and in short, the combination – in this
draft – of broad and
vague authorisation, eligibility of third parties and
bulk access, would
amount to re-creating the *status quo ante *by any other
name. Which
would be interpreted elsewhere as a rejection of the
requirements of GDPR.
------------------------------
CW/16.09.2018
El 12 de septiembre de 2018 a las 8:25 Greg Shatan
<greg@isoc-ny.org>
escribió:
All,
At long last, I attach a draft of the ALAC Statement on
ICANN's proposal
for the framework of a possible Unified Access Model.
Evin, can you please add this to the wiki?
I look forward to comments, questions and proposed
changes to this draft.
Best regards,
Greg
--
Greg Shatan
greg@isoc-ny.org
"The Internet is for everyone"
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