With all due respect to the work that has gone into this, I have to say I am not at all comfortable with going forward with this model as long as the EPDP is working day and night on our behalf to head off some of these potential issues. There is no deadline for comment so maybe we could just table it until the point where it should be reconsidered. Marita On 10/14/2018 3:10 PM, Hadia Abdelsalam Mokhtar EL miniawi wrote:
Dear Greg and all,
I can see on the agenda item 7 assigning an internal deadline for the submission of the comments on the unified access model, first off thank you for the comprehensive comments statement I don't know if it is too late but I have a couple of comments.
With regard to the terms of use, question number 14 the ALAC comment says
"/The statement that WHOIS data “must be used for the purposes [for which] it was provided” points to a potential “Achilles heel” for any plan for access – it depends a great deal on the purposes specified at the time of collection./
/The statement in the proposed model reads/"Terms of Use would establish a framework for the use of non-public WHOIS data by authenticated users accessing non-public WHOIS data through a unified access model, and in particular appropriate limitations on the use of such data, proper procedures for accessing the data, and other safeguards and public policy considerations relating to the responsibilities and practices for the Eligible User Groups. In general, the non-public WHOIS data must be used for the purposes it was provided, and it must not be forwarded to unauthorized third parties."//
My understanding of the above statement is quite different than yours, I understood that the statement is saying that the non-public WHOIS data must be used for the purpose for which the access was provided, i.e for the purpose for which the data was provided to the requestor, the ALAC comment suggests that the proposed statement is saying "WHOIS data must be used for the purpose for which the data was collected" . In my opinion the statement is not referring to the purpose of the collection of the data it is referring to the purpose for which it was made available to the authenticated user. Therefore I don't see the ALAC comment on this part necessary. That being said a clearer language could be required.
My other comment is with regard to question number 8 would a unified access model incorporate transparency requirements? The ALAC comment suggests publishing the list of authenticated users, I don't see how this could possibly be GDPR compliant.
Kind Regards
Hadia
//
*From:*CPWG [mailto:cpwg-bounces@icann.org] *On Behalf Of *Olivier MJ Crépin-Leblond *Sent:* Friday, October 12, 2018 1:11 PM *To:* cpwg@icann.org *Subject:* Re: [CPWG] Meeting Invitation: Consolidated Policy Working Group (CPWG) Call on Wednesday, 17 October 2018 at 13:00 UTC for 90mins
Hello all,
you are probably wondering why we are having such a call since we had not discussed it at the end of our call this week. My mistake: in my haste to finish on time, I forgot this essential agenda item, plus I was under the impression that the Barcelona meeting started next week for some reason; early next week. We chose the earlier time as it is more convenient for me plus several people will already be on the move at the latter time. Kindest regards,
Olivier
On 12/10/2018 15:56, ICANN At-Large Staff wrote:
Dear All,
The next*At-Large**Consolidated Policy Working Group (CPWG) Call*is scheduled for*Wednesday, 17 October 2018 at 13:00 UTC for 90 mins.*
**
For other times:*https://tinyurl.com/y7l65hjg*
The agenda (to be updated) and call details can be found at: *https://community.icann.org/x/Nw28BQ*
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