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
AC
Room: https://participate.icann.org/cpwg/
ADIGO
Conference Bridge:
EN: 3535
Toll-free
access number (US and Canada): 800 550 6865
Other
toll-free numbers: http://adigo.com/icann/
At-Large
Consolidated Policy Working Group (CPWG) Wiki Space: https://community.icann.org/x/jYDpB
If
you require a dial-out please contact At-Large staff at: staff@atlarge.icann.org
Thank
you.
Kind
regards,
At-Large
Staff
ICANN
Policy Staff in support of the At-Large Community
Website: atlarge.icann.org
Facebook: facebook.com/icannatlarge
Twitter: @ICANNAtLarge
_______________________________________________
CPWG mailing list
CPWG@icann.org
https://mm.icann.org/mailman/listinfo/cpwg