July 2017 - Gdd-gnso-ppsai-impl

Topics for tomorrow's PP IRT meeting
by Amy Bivins Aug. 1, 2017

Aug. 1, 2017

Hello, All, At tomorrow's privacy/proxy IRT meeting (1400 UTC), we will be discussing: * The data escrow specification in the draft PPAA; and * The issues raised last week regarding the amendment process in the draft PPAA. We will do a live poll to rank the PPAA issues that have been raised to date for discussion (by staff and IRT members) so that we can create a schedule for these discussions. I hope you all can make it. I've attached an updated issues list to add the items raised on the list over the weekend. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Action items (including poll) from today's PP IRT call
by Amy Bivins July 31, 2017

July 31, 2017

Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. I've attached an updated issues list that includes notes from our discussions today. To summarize for those who could not attend, we discussed the draft PPAA data escrow specification, amendment process, and priorities for upcoming IRT discussions regarding the agreement. To ensure we have a complete record of IRT member views surrounding the data escrow specification, we are re-polling the group. Please complete this poll no later than next Friday, 4 August. We are allowing over a week to complete this poll to ensure that all IRT members have adequate time to consider this issue and provide your input. There is only one substantive question. The results of this poll, coupled with the IRT discussions on the topic to date, will be used to determine the final IRT view on this topic. Thus, it is important that you participate if you want your opinion heard. The poll is available at https://www.surveymonkey.com/r/62XCMSS. As a reminder on the background of this provision, the Final Report does not explicitly mention data escrow, but seems to contemplate that data escrow would be an element of this accreditation program. The 2013 RAA's interim specification on privacy and proxy registration<https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#pri…>s includes data escrow requirements. IRT members in attendance at the 28 February IRT meeting and discussing the topic on-list confirmed that this program should have data escrow requirements built into it, https://community.icann.org/display/IRT/28+February+2017 The poll also asks you to identify other sections of the PPAA that you would like to discuss in detail in an upcoming IRT meeting. However, please note that any and all comments related to the PPAA draft are also welcome on the list anytime. Based on the IRT discussion and poll today, we are planning to discuss the following topics in August. Please consult the attached issues list to see specific questions related to this topic: 1 August: Provider Suspension (Issue 13); Contact Information (Issue 9); Reveal Requirements (Issue 10); Code of Conduct (Issue 5); Domain Name Cancellation (Issue 6) 8 August: LEA Framework Specification (Issues 17-19); Data Retention (Issues 4, 23) (This is pending confirmation of PSWG availability to attend this meeting) 15 August: Definitions (Issue 1); Amendment Process (Issues 2, 3, pending updates following 25 July IRT discussion); RAA Synchronization (Issue 21) 22 August: Any issues not reached above, plus additional topics recommended by IRT in poll and on-list 29 August: Data Escrow (Issue 14, pending results of IRT discussions and poll); Labeling (Issue 16) Please send any additional input on the topics discussed this week to the list prior to our next meeting. For next week, please come prepared to discuss the topics identified above under 1 August (and please feel free to share any comments with the group beforehand on-list). Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Agreement comments
by theo geurts July 25, 2017

July 25, 2017

Hi all, Attached my comments on the agreement. Overall the agreement is in pretty good shape. A few sections are somewhat problematic. Section 2.3 Domain Name Resolves to Website Where Trademark Is Allegedly Infringed coupled with Section 3. Provider Action on Request. Perhaps it is me, but I have this fear that these two sections will create a lot of manual labor on the Registrar/provider side? Or has the potential to create a ton of work. Again maybe it is me, some input from Registrars or WG members is very welcome. Perhaps this was the intention of the WG; I am not sure. SPECIFICATION 6: DATA RETENTION SPECIFICATION Maybe I just have grown a healthy distaste when it comes to waiver processes, but do we require a data retention spec for a privacy service? Thanks, Theo Ps, that agreement is a very long read......

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Data escrow question WAS RE: Action Items From Today's PP IRT Call
by Metalitz, Steven July 24, 2017

July 24, 2017

With the hope of jump-starting a bit the data escrow discussion that is teed up for Tuesday, let me share with the list the question I raised on this morning's brief attempted call of the subteam re unaffiliated providers. The data escrow provisions in the draft accreditation agreement are quite complex and detailed, amounting to a 5-page specification. We are told this specification is drawn from the standard gTLD registry agreement. By contrast, the data escrow obligations in the Registrar Accreditation Agreement are boiled down to a single paragraph (section 3.6). Since all the p/p providers that have engaged in the WG and in the IRT are affiliated with accredited registrars, we have sought to maximize the situations in which these providers may be able to "piggy-back" on obligations already undertaken by registrars, in order to minimize unnecessary duplication of effort. Data escrow would appear to be an excellent candidate for this treatment as well. Perhaps RAA section 3.6 could be adapted for the p/p accreditation context. (Of course, if the RAA provision is modified in the future to align more closely with the registry obligations, the p/p obligations may be able to move in lockstep with it.) Of course this is not a complete solution, we would still have to look at the obligations for unaffiliated providers, but at least for the affiliated ones this seems more efficient. So my question is, what is the downside of this approach? Put another way, what would be the advantage gained by aligning the p/p escrow obligations with those of registries, rather than those of registrars? Amy perhaps you can also pass this question on to the ICANN technical staff that will be on Tuesday's call, so that they can respond to it on this list, or if not, on Tuesday's call. Thanks all and have a good weekend. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, July 18, 2017 11:36 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: * Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached). Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Action Items From Today's PP IRT Call
by Amy Bivins July 20, 2017

July 20, 2017

Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: * Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached). Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Draft PPAA materials attached for tomorrow's IRT call
by Amy Bivins July 18, 2017

July 18, 2017

Dear Colleagues, Attached, you will find documents related to the IRT's review of the draft Privacy and Proxy Service Provider Accreditation Agreement. We will discuss each of these items and the process for reviewing the draft PPAA during tomorrow's IRT call, scheduled for 18 July at 1400 UTC. Please plan to attend. Please find attached: 1. Draft PPAA 2. Draft PPAA issues list 3. Draft PPAA "suggested modification" form 4. Document mapping Final Recommendations to draft PPAA and draft Policy document During tomorrow's call, we will discuss: * An overview of the draft PPAA * The planned process for IRT review of the PPAA * An overview of the PPAA issues list * The status of parallel work (subteam 3 and upcoming work related to the Transfer Policy) I look forward to speaking with you tomorrow! Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Re: [Gdd-gnso-ppsai-impl] Updated PSWG framework draft, action items from today's IRT call
by Darcy Southwell July 13, 2017

July 13, 2017

Thanks, Amy. I hope you can encourage ICANN Legal to share the draft accreditation agreement well in advance of next Tuesday’s meeting. Without being able to review it in advance, meeting participants will not be able to provide any substantive feedback or questions or engage in meaningful dialogue. Best, Darcy From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Amy Bivins <amy.bivins(a)icann.org> Reply-To: <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday, July 11, 2017 at 11:39 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Updated PSWG framework draft, action items from today's IRT call Hello, All, Thanks so much for your participation on the PP IRT call today. I’ve made one final edit to the draft LEA framework document per our discussion (See section 3.1). Any comments/suggestions on that section are welcome! In the update, I did not reference any specific type of contact that was discussed on the call, and left it as “designated contact.” If you think examples would be helpful to provide added clarity that the contact could be a form or any other means, please feel free to suggest line edits. I am checking with the internal team as to whether/when I can share the draft accreditation agreement prior to next week’s call, and will share any updates I can get on that as soon as possible. In the interim, if you have questions or comments, please don’t hesitate to ask. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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Updated PSWG framework draft, action items from today's IRT call
by Amy Bivins July 12, 2017

July 12, 2017

Hello, All, Thanks so much for your participation on the PP IRT call today. I've made one final edit to the draft LEA framework document per our discussion (See section 3.1). Any comments/suggestions on that section are welcome! In the update, I did not reference any specific type of contact that was discussed on the call, and left it as "designated contact." If you think examples would be helpful to provide added clarity that the contact could be a form or any other means, please feel free to suggest line edits. I am checking with the internal team as to whether/when I can share the draft accreditation agreement prior to next week's call, and will share any updates I can get on that as soon as possible. In the interim, if you have questions or comments, please don't hesitate to ask. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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Re: [Gdd-gnso-ppsai-impl] Agenda, materials for 11 July PP IRT call
by Darcy Southwell July 11, 2017

July 11, 2017

My apologies, but I have a conflict for today’s meeting. Darcy ---------------- Darcy Southwell | Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Amy Bivins <amy.bivins(a)icann.org> Reply-To: <gdd-gnso-ppsai-impl(a)icann.org> Date: Wednesday, July 5, 2017 at 10:50 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda, materials for 11 July PP IRT call Dear Colleagues, This is a reminder that the Privacy/Proxy Service Provider Accreditation Program IRT’s next meeting is scheduled for 11 July, at 1400 UTC. Login details were distributed separately with the calendar invitation. Next week, we will continue the discussion with Nick Shorey and any other PSWG members who are in attendance regarding the draft LEA disclosure framework. A draft redline is attached—this document has been updated to reflect the group’s discussions at ICANN59. We are hoping to, at a minimum, continue discussing Section 3.1 (the designated LEA contact, and options for how a provider could share that contact with the relevant authorities without publishing it on the provider’s website) and Section 3.2.1, regarding the IRT’s proposal to extend the time for a Provider to review each law enforcement request from 24 hours (proposed by the PSWG) to 2 business days in the Provider’s jurisdiction. To the extent there is remaining time, we can also discuss any other topics you would like to raise with the PSWG regarding this proposal. I hope you all can make it! If you have comments, please don’t hesitate to bring them up on the list before the call. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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Agenda, materials for 11 July PP IRT call
by Amy Bivins July 5, 2017

July 5, 2017

Dear Colleagues, This is a reminder that the Privacy/Proxy Service Provider Accreditation Program IRT's next meeting is scheduled for 11 July, at 1400 UTC. Login details were distributed separately with the calendar invitation. Next week, we will continue the discussion with Nick Shorey and any other PSWG members who are in attendance regarding the draft LEA disclosure framework. A draft redline is attached-this document has been updated to reflect the group's discussions at ICANN59. We are hoping to, at a minimum, continue discussing Section 3.1 (the designated LEA contact, and options for how a provider could share that contact with the relevant authorities without publishing it on the provider's website) and Section 3.2.1, regarding the IRT's proposal to extend the time for a Provider to review each law enforcement request from 24 hours (proposed by the PSWG) to 2 business days in the Provider's jurisdiction. To the extent there is remaining time, we can also discuss any other topics you would like to raise with the PSWG regarding this proposal. I hope you all can make it! If you have comments, please don't hesitate to bring them up on the list before the call. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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