February 2018 - Gdd-gnso-ppsai-impl

Doc's for 2/13 PPSAI IRT call?
by Metalitz, Steven Feb. 12, 2018

Feb. 12, 2018

Hello Amy, In the run up to tomorrow's call I am checking on the status of the 2 documents you referenced in the message below as likely to be ready for review by the IRT by then: (1) One additional specification to review, related to the proposed format for monthly reporting (2) Updates to the draft Policy document, de-accreditation process document, and Applicant Guide based on the IRT's input Thanks in advance for the latest on this. 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, January 30, 2018 11:14 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Action items, next steps following today's IRT call Dear Colleagues, Thank you for your participation on today's privacy/proxy IRT call. If you couldn't attend, I encourage you to listen to the (very short) recording, available on the wiki, https://community.icann.org/display/IRT/30+January+2018<https://community.icann.org/display/IRT/30+January+2018> Today, we reviewed proposed edits to Specification 5, including the addition of the following text from the Final Report to the specification's introduction (see p. 85 of the Final Report), "Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy." Barring any further IRT discussion on this change, or the other following typographical changes throughout the specification, we will make these edits to the next PPAA draft: * Updating references to "WHOIS" to "RDDS" throughout the specification; * Updating the word "Policy" to "Specification" throughout the specification; * Changing the word "trademark" to "copyright" in Section 32.2.7.4<http://32.2.7.4>. We also reviewed the previously agreed-upon plan to publish the draft data retention specification as-is, with the understanding that this could be impacted at a later date by the parallel GDPR work that is currently underway. Please send any further input you have on these items to the list this week. Next Steps We have one additional specification to review, related to the proposed format for monthly reporting (we expect this will mostly be of interest to the registrar members of the IRT). If this is ready next week we will review but, if not, we may cancel next week's meeting. I'll let you know by the end of this week. Meanwhile, ICANN Org is finalizing updates to the draft Policy document, de-accreditation process document, and Applicant Guide based on the IRT's input. I expect to be able to share these with you next week, for discussion the following week (the week of 13 February). I hope to be able to share the next PPAA draft with you the week of 13 Feb, for final IRT review over the following couple of weeks. Once these materials have been reviewed by the IRT, we will be ready for public comment. Our hope is to publish these for comment by the end of February, or at least prior to ICANN61. We have requested an IRT meeting slot for ICANN61, but do not have a date/time confirmed yet. Provided we are out for comment at that point, we plan to discuss the remaining Transfer Policy issue during that meeting. 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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Request for IRT Feedback: LEA Framework Specification, Receipt Process's Application to High Priority Requests
by Amy Bivins Feb. 5, 2018

Feb. 5, 2018

Dear Colleagues, As mentioned on the list a couple of weeks ago, the current draft PPAA is still a bit ambiguous regarding how the review process outlined in Section 3.2.1 applies to high priority requests. We need ensure that the draft is clear about this requirement when we go out for public comment (and if there is opposition to the proposed requirement by any members of the IRT, this will be flagged in the call for comments). Upon reviewing the IRT's input to date, I am proposing an edit that I believe reflects the IRT discussion on this point. Please review and provide your comments on this proposed language no later than this Friday, 9 February. To summarize, the current draft contains a two-step process for Providers upon receipt of a request from LEA. (1) Within two business days, the Provider must review the request and confirm to the LEA requester that it has been received and contains the relevant information required to meet the minimum standard for acceptance (See 3.2.1 of Specification 4). (2) The Provider must then action the request in accordance with the priority level (within 24 hours for "high priority" requests (4.1.2); or within the timeline requested by LEA, if possible, for other requests (See 4.1.3). The current language may be a bit ambiguous as to whether the two business day "review period" applies before the 24-hour period for responding to high priority requests (as explained in more detail in the attached message). The view of registrar IRT members appears to be that requiring action within 24 hours of receipt of an LEA request, even if it is a high priority request, is unacceptable. PSWG members of the IRT disagree. Other IRT members appear to have mixed views on this (some referenced the RAA requirement that "Well-founded reports of Illegal Activity submitted to these [dedicated LEA] contacts must be reviewed within 24 hours by an individual who is empowered by Registrar to take necessary and appropriate actions in response to the report." Registrar members of the IRT said that the RAA-required review is less intensive than the PPAA review due to the specific requirements in the PPAA draft). Based on the views expressed within the IRT, it appears that one potential solution to this ambiguity would be to update Section 4.1.2 to state that (proposed edit in red), "Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours of completion of the receipt process outlined in Section 3.2." The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority." The practical impact of this proposed change would be that the provider must action a high priority request within 24 hours of determining that the request meets the minimum standard for acceptance. If the provider completes the receipt process sooner than 2 business days after receipt of the request, this would start the 24-hour clock for actioning the request. Thus, this could shorten the response window a bit, partially addressing the PSWG concerns of a "two business days plus 24 hours" requirement, while also addressing registrar concerns by not starting the clock until the provider has time to review the request, if the full time of the receipt process is required to conduct that review. Please provide your feedback on this proposed change no later than this Friday, 9 Feb. And if you have further comments on this, please share those as well. 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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Canceled--PP IRT meeting scheduled for 6 Feb
by Amy Bivins Feb. 2, 2018

Feb. 2, 2018

Dear Colleagues, The Privacy/Proxy IRT meeting scheduled for 6 February has been canceled. We will reconvene the following week, 13 February. Please watch your inboxes, as updated materials should be distributed for your review and discussion on 13 February by the end of next week. Best (and have a great weekend!), 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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