- Gdd-gnso-ppsai-impl - lists.icann.org

PP IRT Action Items This Week
by Amy Bivins 17 Sep '18

17 Sep '18

Dear Colleagues, ICANN org is continuing to review your feedback on the PPAA draft, and I hope to have an update this week as to your specific feedback on the data processing provisions. In the interim, please provide any feedback you have on the following no later than your end of day on Friday, 21 Sept: 1. In Specification 3, do you have any issue with incorporating a definition of action/actioned? We have attempted to clarify the term in Section 3.2.3 (p. 52) to state "action, in accordance with Sections 4.1 and 4.2..." but we believe this could be made more clear by explicitly defining this term. For example, we could add a definition that states that action means "to disclose the Requested Information, to refuse in writing to disclose the Requested Information, and/or to inform the LEA Requester that more time is required to respond to the request." 2. Should we add a new explicit basis for a Provider to reasonably refuse to disclose Requested Information in Specification 3, Section 4.1, where the Provider has a basis for reasonably believing that such Disclosure would violate relevant data protection law? 3. In Specification 4 (p. 62)-should this section title be updated since it doesn't specifically address how to resolve disputes? In addition, does the IRT wish to review the meaning and intent of this section in light of data subject rights in the GDPR, and its relevance to resolving disputes concerning data protection matters? 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 Standing Call Time
by Amy Bivins 13 Sep '18

13 Sep '18

[Web Meeting] [Sponsor] Dear Colleagues, Please note that the standing call time for the Privacy and Proxy Service Provider Accreditation Program Implementation Review Team is now Thursdays at 1600 UTC. Individual occurrences will be canceled on weeks where a meeting will not be held. Adobe Connect: https://participate.icann.org/ppirt/ __________________________________________________________________ You're Invited. You've been invited to a GlobalMeet® phone only meeting. Have the meeting call you. Click the Connect Me link below. No need to dial-in. Connect Me <https://go.conferencinghub.com/2y4ql> Not at your computer? You can join by dialing one of the access numbers below. Mobile: tel://1-605-475-5618,*,,1350875547#<tel://1-605-475-5618,*,,1350875547> Phone Only Controls: https://go.conferencinghub.com/2y4ql Primary Access Number: 1-605-475-5618 Guest Passcode: 135 087 5547 Additional Access: USA 1-605-475-5618 USA 1-719-325-2630 Canada, Calgary +1 403 407 5780 Canada, Montreal +1 514 669 5909 Canada, Toronto +1 416 915 3615 Canada, Vancouver +1 604 205 5118 Argentina, Buenos Aires +54 (0) 11 5172 6019 Argentina (toll free) 0800 800 1250 Australia, Sydney +61 (0) 2 8017 6391 Australia, Melbourne +61 (0) 3 8687 0614 Australia, Brisbane +61 (0) 7 3015 0608 Australia (toll free) 1 800 720 493 Austria, Vienna +43 (0)1 928 2722 Austria (toll free) 0800 070 841 Bahrain, Manama +973 1650 0402 Bahrain (toll free) 8008 1214 Belarus (toll free) 8 820 0011 0353 Belgium, Brussels +32 (0) 2 400 1980 Belgium (toll free) 0800 39 268 Bosnia and Herzegovina +387 7031 1461 Brazil, Sao Paulo +55 11 4935 7122 Brazil, Rio de Janeiro +55 21 4560 0023 Brazil (toll free) 0800 887 0283 Bulgaria, Sofia +359 (0) 2 491 7244 Bulgaria (toll free) 00800 111 4944 Cambodia, Phnom Penh +855 23 962 579 Canada (toll free) 1 855 950 3706 Chile, Santiago +56 (0) 2 2666 0711 Chile (toll free) 171 800 835 943 China (national) +400 681 8104 China, Beijing +86 10 5667 0005 China, Shanghai +86 21 2039 7079 Colombia, Bogota +57 1 508 8112 Colombia (toll free) 01 800 755 0043 Costa Rica (toll free) 800 542 5331 Croatia (toll free) 0800 223 004 Cyprus (toll free) 800 97400 Czech Republic, Prague +420 225 986 505 Czech Republic (toll free) 800 701 236 Denmark, Copenhagen +45 32 71 16 70 Denmark (toll free) 80 70 35 78 Egypt (toll free) 0800 000 0401 Estonia, Tallinn +372 622 6519 Estonia (toll free) 800 011 1569 Fiji (toll free) 00800 3317 Finland, Helsinki +358 (0) 9 2310 1611 Finland (toll free) 0800 772 230 France, Paris +33 (0) 1 76 77 22 50 France (toll free) 0800 946 112 France (national) 0811 655 134 France (national) 0821 231 687 Georgia, Tbilisi +995 32 2 053 082 Germany, Frankfurt +49 (0) 69 5060 9515 Germany, Munich +49 (0) 89 24443 2900 Germany (national) 01801 001 378 Germany (toll free) 0800 588 9225 Greece, Athens +30 211 181 3815 Greece (toll free) 00800 128 811 Hong Kong +852 3018 9103 Hong Kong (toll free) 800 968 082 Hungary, Budapest +36 1 808 8134 Hungary (toll free) 068 001 9662 Iceland (toll free) 800 9841 India, Delhi +91 11 6310 0272 India, Mumbai +91 22 6310 0274 India, Chennai +91 44 6310 0227 India, Bangalore +91 80 6760 8747 India (toll free) 1800 3010 1564 Indonesia, Jakarta +62 21 2188 9079 Indonesia (toll free) 007 803 321 8120 Ireland, Dublin +353 (0) 1 246 5614 Ireland (national) 0818 270 287 Ireland (toll free) 1800 937 695 Ireland (national) 1890 907 722 Israel, Tel Aviv +972 (0)3 763 0384 Israel (toll free) 180 921 2890 Italy, Milan +39 02 3046 4837 Italy, Rome +39 06 4523 6635 Italy (toll free) 800 148 288 Japan, Tokyo +81 3 4560 1274 Japan, Osaka +81 6 4560 0303 Japan (mobile) 0120 270 611 Japan (toll free) 0120 286 011 Japan (national) 0570 005 744 Jordan (toll free) 0800 22156 Kazakhstan (toll free) 8800 333 7552 Kenya, Nairobi +254 (0)207 643 596 South Korea, Seoul +82 (0) 2 6007 0072 South Korea (toll free) 007 986 136 2233 Kuwait (national) +965 2206 3083 Latvia, Riga +371 6778 2598 Latvia (toll free) 8000 4374 Lithuania, Vilnius +370 5205 5239 Lithuania (toll free) 8800 31445 Luxembourg +352 2730 2276 Luxembourg (toll free) 800 28428 Macau (national) +853 6262 1674 Malaysia, Kuala Lumpur +60 (0) 3 7723 7140 Malaysia (toll free) 1 800 815 805 Mexico, Guadalajara +52 33 4162 5891 Mexico, Mexico City +52 55 8421 0857 Mexico, Monterrey +52 81 4770 2472 Mexico (toll free) 01 800 283 3129 Morocco, Casablanca +212 (0)520 480 128 Morocco (toll free) 0800 092 258 Netherlands, Amsterdam +31 (0) 20 716 8266 Netherlands (toll free) 0800 020 0593 New Zealand, Christchurch +64 (0) 3 974 2597 New Zealand, Wellington +64 (0) 4 909 4676 New Zealand, Auckland +64 (0) 9 929 1769 New Zealand (toll free) 0800 459 127 Nigeria, Lagos +234 1 277 5140 Norway, Oslo +47 2162 4054 Norway (toll free) 800 58459 Oman (toll free) 800 77269 Pakistan, Islamabad +92 5181 08874 Panama, Panama City +507 8 339 782 Panama (toll free) 00800 223 1430 Peru, Lima +51 (0) 1 700 9587 Peru (toll free) 0800 78125 Philippines, Manila +63 (0)2 395 3365 Philippines (toll free) 1800 111 017 51 Poland, Warsaw +48 22 295 3504 Poland (toll free) 00800 121 4340 Portugal, Lisbon +351 21 316 4041 Portugal (toll free) 800 784 434 Qatar (freephone) 00 800 100 499 Romania, Bucharest +40 (0) 21 529 3969 Romania (toll free) 0800 801 030 Russia, Moscow +7 495 213 0988 Russia (toll free) 8 800 500 9319 Saudi Arabia (toll free) 800 844 4963 Saudi Arabia (toll free) 800 850 0227 Serbia (toll free) 0800 190 698 Singapore +65 6654 9111 Singapore (toll free) 800 616 3175 Slovakia, Bratislava +421 (0)2 3321 5333 Slovakia (toll free) 0800 001 661 Slovenia, Ljubljana +386 1 600 1622 Slovenia (toll free) 0800 80994 South Africa, Johannesburg +27 (0)11 019 7087 South Africa (toll free) 0800 988 886 Spain, Madrid +34 91 114 6640 Spain, Barcelona +34 93 800 1935 Spain (toll free) 900 803 689 Sri Lanka, Sri Lanka +94 720 910 348 Sweden, Stockholm +46 (0) 8 5065 3944 Sweden (toll free) 0200 125 456 Switzerland, Geneva +41 (0) 22 595 4857 Switzerland, Zurich +41 (0) 44 580 7246 Switzerland (toll free) 0800 841 702 Taiwan, Taipei +886 (0) 2 2656 7213 Taiwan (toll free) 00 801 615 184 Thailand, Bangkok +66 (0) 2104 0767 Thailand (toll free) 1 800 012 172 Tunisia, Tunis +216 31 378 109 Turkey, Istanbul +90 212 375 50 13 Turkey (toll free) 00 800 448 828 358 Ukraine (toll free) 0800 500 732 UAE (toll free) 8000 3570 2638 UK (03) +44 (0)330 336 6010 UK (toll free) 0800 368 0950 UK (national) 0844 473 5003 UK (national) 0845 545 0040 USA /Canada (toll free) 1-855-747-8824 Uruguay (toll free) 0004 019 0561 Venezuela, Caracas +58 212 720 2342 Venezuela (toll free) 0800 102 9660 Vietnam, Hanoi +84 24 4458 3323 Vietnam, Ho 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Materials From Today's PP IRT Meeting
by Amy Bivins 13 Sep '18

13 Sep '18

Dear Colleagues, Thank you for your active participation on today's PP IRT call. The call recording and related materials are now available on the wiki, https://community.icann.org/display/IRT/13+September+2018 For those who could not attend, I encourage you to review the recording. We were able to complete our discussion of IRT feedback that has been received on the PPAA markup. If anyone has additional feedback on the topics discussed today, please send it to the list this week, if possible. I'm referring your feedback to the internal team as we receive it, and will have an update on timeline on completing this round of review of the issues raised as soon as possible. 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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PPAA draft markup for today's meeting
by Amy Bivins 13 Sep '18

13 Sep '18

Dear Colleagues, I've attached an updated PPAA draft that incorporates all of the new feedback received since our last meeting. We're planning to pick up at Section 3.5.3.3 today and get as far as we can on the feedback we've received. As a reminder, our call is at 1600 UTC today. The Adobe Connect room is https://participate.icann.org/ppirt/ . Thanks in advance for your active participation, and I look forward to speaking with you later today. 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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Materials, discussion topics for this week's PP IRT meeting
by Amy Bivins 12 Sep '18

12 Sep '18

Dear Colleagues, Thank you for your feedback on the list since our last meeting. We will continue to discuss your feedback on the PPAA draft during our next PPIRT meeting on Thursday, 13 September, 1600 UTC. The most recent PPAA draft, including comments received on the list since our last meeting, is attached. Action Item: The purpose of our call this week is to continue reviewing your feedback on the PPAA draft. We will pick up at Section 3.5, where we adjourned last week. If you have any additional items that you would like to note in this week's discussion version of the draft (for display in the AC room), please send them to the list no later than your end of day Wednesday. Action Item: We'd also like to hear any feedback you have on the possibility of adding a PPAA provision(s) to require provider logging of third-party requests for non-public RDDS data. Please consider this possibility and share any feedback you have on the list this week or during Thursday's call. I'm attaching a screenshot of the results of the PP IRT poll. Of the 15 IRT members who responded to the poll: * Nine IRT members answered "yes" to the question, "Do you believe that the Privacy and Proxy Service Provider Accreditation Program Implementation Review Team should consult with the GNSO Council prior to proceeding to public comment due to one or more Policy questions surrounding the implementation of the Final Recommendations?" (8-registrar; 1-no affiliation provided) * Six IRT members answered "No." (2-PSWG, 1-registrar, 2-IPC, 1-BC) Your feedback on the PPAA draft and all other issues is being shared with the broader internal team for review. I won't have official feedback to share this week, but am hoping that there will be more to share next week. 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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Materials From Today's PP IRT Call, Action Items
by Amy Bivins 09 Sep '18

09 Sep '18

Dear Colleagues, Thanks for your active participation on today's PP IRT call. If you didn't attend, I encourage you to review the materials and recording, which are available on the wiki, https://community.icann.org/display/IRT/6+Sept+2018+Meeting. Notes and Action Items 1. The first item on today's agenda was a discussion of the feedback and comments from some members of the IRT that the current RDDS environment might signal a need to consult with the GNSO Council about the status of the PP IRT's work. IRT members were asked whether they believe questions exist that should be taken to the Council and, if so, what the questions are. IRT members are encouraged to review the recording to hear their all positions raised on this item. * Action Item 1: If any IRT member believes that one or more Policy issues have arisen that should be referred to the GNSO Council, the member is requested to clearly identify that question on the list no later than the end of the day on Friday. * Action Item 2: IRT members are requested to provide feedback on any issues raised via the list. * Action Item 3: IRT members are also invited to, either instead of writing to the list or as a supplement, indicate their position on whether or not they believe a Policy issue has arisen that should be escalated to the Council, by participating in this poll: https://www.surveymonkey.com/r/8MW2JMM Please complete the poll by the end of this week. I will circulate the results of the poll on Monday. The poll results will be considered along with feedback received on the list and the call. * If the results of the poll and continued discussion on the list this week indicate that there is a likely consensus to escalate one or more issues to the Council, this potential course of action will be continued to be explored next week. If not, we will continue to work to finalize the PPAA in preparation for public comment. 2. PPAA Markup * We began reviewing the PPAA markup, and will continue reviewing next week. * Action Item: IRT members are invited to continue reviewing the markup and provide any additional feedback on the document no later than end of day Monday for discussion on Thursday's call. * Action Item: I will consult with Legal about points raised on the call, for discussion next week. 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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PP services for gated access data
by Roman, Peter (CRM) 06 Sep '18

06 Sep '18

All – Just to continue the smaller discussion from today’s call: Putting aside the existential question of whether the business case for privacy/proxy makes sense following the implementation of the GDPR, and assuming that: 1) privacy/proxy providers will continue to do business and 2) the EPDP is going to reach a solution that will give IP rights holders, cybersecurity researchers, law enforcement, and other vetted people access to the registrant data that is not publicly available; I propose that the IRT consider that, since the second tier of WHOIS data would only be available to vetted, accredited law enforcement, cybersecurity, IP rights holders, etc. that have represented that they have a legitimate purpose for accessing the data, and since that data is merely subscriber data (which under the Council of Europe’s CyberCrime Convention, and numerous other legal regimes as well, is deserving of the lowest level of privacy protection), and therefore no legitimate purpose is served by further hindering access to such data, the IRT should add the following language to the draft PPAA: 3.5.7 Provider shall not provide Services for Customers whose data is non-public. Or 3.5.7 Provider shall not provide Services for Customers whose data is only accessible through gated access in the RDDS system and is not publicly available through WHOIS. Thanks, Peter Roman Senior Counsel Computer Crime & Intellectual Property Section Criminal Division Department of Justice 1301 New York Ave., NW Washington, DC 20530 (202) 305-1323 peter.roman(a)usdoj.gov<mailto:peter.roman@usdoj.gov> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Theo Geurts Sent: Thursday, August 30, 2018 3:08 AM To: gdd-gnso-ppsai-impl(a)icann.org; Michele Neylon - Blacknight <michele(a)blacknight.com> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for tomorrow's PP IRT meeting are attached Agreed on the moving target part. Not too mention another moving target that will render most of our work right down into the trash if it happens. http://domainincite.com/23371-could-a-new-us-law-make-gdpr-irrelevant This draft seems to be in direct conflict with some of the WG's recommendations; https://via.hypothes.is/https://www.internetgovernance.org/wp-content/uploa…<https://via.hypothes.is/https:/www.internetgovernance.org/wp-content/upload…> Thanks, Theo On 30-8-2018 7:55, Michele Neylon - Blacknight wrote: I won’t be able to attend as I’m at an event. I also agree with the concerns raised by others about pegging *anything* to a moving target, which the Temp Spec is TLDR – it’s not policy – it’s a stopgap. Baking it into anything else is a really bad idea Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins(a)icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl(a)icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Wednesday 29 August 2018 at 16:22 To: "gdd-gnso-ppsai-impl(a)icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl(a)icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials for tomorrow's PP IRT meeting are attached Dear Colleagues, This is a reminder that the PP IRT will meet tomorrow, Thursday, 30 August, at 1600 UTC. A draft markup of the PPAA is attached. This markup is for discussion purposes only—it is not a final proposal and remains subject to revision. The draft is being circulated, without further delay, to continue the conversation. It has not been approved by senior management and is for discussion only. We would like to begin discussing the following topics tomorrow (but please feel free to comment before then on the list): (1) Some suggested edits track what’s in the Temporary Specification for gTLD Registration Data. For example, section 3.5.3.3. How should we approach drafting provisions modeled on the Temp Spec, given that its language is subject to change in the near future? (2) The disclosure frameworks seem to be written from the position that there’s no discretion for the Provider to not provide the underlying customer data if the conditions in the framework are met. Is this the intent? This could potentially cause issues under the GDPR, because this doesn’t seem to leave room to balance the interests of the data subjects with the legitimate interest of the parties requesting personal data. (3) The disclosure frameworks raise additional GDPR-related questions that are similar to questions raised in the Draft Framework Elements of a Potential Unified Access Model<https://www.icann.org/en/system/files/files/framework-elements-unified-acce…> paper published by ICANN org. For example, what would the requirements be for logging requests for disclosure made under the frameworks (or even requests not governed by the frameworks)? (4) Do you see any other issues that you believe must be addressed related to GDPR that were not addressed in this markup? (5) Following the completion of the IRT’s review of this draft accreditation agreement and related matters, we believe are ready to proceed to public comment. Do you believe there is any reason why the IRT should not proceed to public comment? (6) We have heard questions from various members of the community about how the proposed accreditation program requirements will operate within the current Temp Spec RDDS environment. These proposed program requirements do not address how PP registrations interact with a gated access model or how they might be impacted, if at all, by the results of the EPDP. Is this an issue that the IRT believes should be explored at this stage? If any member of the IRT wishes to raise any comments or points about this topic, you are encouraged to do so during the IRT call or via the list. One area that may need further attention in the agreement is specifically defining what data is to be collected and for what purpose. In addition, the new Specification 8 contains some data processing requirements, but additional discussion is needed on the appropriate controller arrangements that are needed between ICANN, the registrar and the Provider. 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> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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Updated PPAA draft including all new comments from list
by Amy Bivins 06 Sep '18

06 Sep '18

Dear Colleagues, Attached is an updated PPAA draft that incorporates all of the proposed edits (and comments about those proposed edits) received on the list this week. I look forward to speaking with you later today. 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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Agenda, materials, poll for tomorrow's PP IRT meeting
by Amy Bivins 06 Sep '18

06 Sep '18

Dear Colleagues, This is a reminder that the PP IRT will meet tomorrow, 6 Sept, at 1600 UTC. Adobe Connect: https://participate.icann.org/ppirt/ I'm attaching the current markup of the PPAA, showing all IRT feedback received thus far on the GDPR-related markup. Please note that all edits proposed by Volker have also been supported by Theo, Sara, Chris, and Eric. Agenda: 1. Discussion Topic 1: Do you believe that the Privacy and Proxy Service Provider Accreditation Program Implementation Review Team should consult with the GNSO Council prior to proceeding to public comment due to one or more Policy questions surrounding the implementation of the Final Recommendations? * Background: Please note that ICANN Legal has advised that data processing provisions are necessary in PPAA (as proposed in Section 3.5.3.3 and Specification 8), though the current text may be edited based on IRT feedback. * Draft WHOIS2 Report: Also, please note that the impact of GDPR on PP was raised in the WHOIS2 draft report that was published yesterday for public comment, https://www.icann.org/en/system/files/files/draft-rds-whois2-review-31aug18… (see p. 67-9). The report said that GDPR and other privacy regimes might reduce the apparent need for PP services, but that this impact would have to be assessed in concert with any future review of the effectiveness of the policy. The report also raised points related to fees and the time that was required for the recent Legal review. The report had recommendations for additional steps to be taken if this accreditation program is not implemented by 31 December 2019. * Action item: Please complete poll to determine level of IRT consensus on this topic no later than this Friday, 7 Sept: https://www.surveymonkey.com/r/8MW2JMM 2. Discussion Topic 2: IRT feedback on PPAA draft (attached). We will begin with the IRT feedback on Specification 8 and then return to the beginning of the agreement and proceed as far as we can on feedback received thus far during 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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Follow-Up on Yesterday's PP IRT Discussion
by Amy Bivins 06 Sep '18

06 Sep '18

Dear Colleagues, Following up on our discussion yesterday, I checked with the Legal team about a couple of items that were discussed. 1. With respect to the proposed edits to the PPAA that are related to data processing (see, e.g. Section 3.5.3 of the contract and the new draft Specification 8), provisions on these topics must be included in this contract, though these can be edited based on your feedback. If you have suggested edits to these new provisions, please send them to the list and we can discuss them on the call next week. If, as discussed yesterday, you believe the inclusion of these provisions raises more fundamental questions about status, in light of the pending ePDP on similar topics, we can also discuss that. As a reminder, the way the PPAA is drafted, any new ICANN Policy that is in conflict with current provisions (GDPR-related or otherwise) would supersede any conflicting provisions in this contract. 1. On the overall timeline, and additional deliverables, any additional GDPR-related changes will be based on IRT feedback. We have a couple of additional discussion topics that we didn't reach last week, which could require additional PPAA changes. We'll discuss these next week: * Are the disclosure frameworks intended to give Providers limited or no discretion on disclosure if other requirements in the framework are met? * What should requirements be for a Provider's logging of disclosure requests from third parties? We are continuing to review the contract for any copy-editing related issues, and I expect we will finish with those in the next week or so. I hope this is helpful. Please continue to consider these issues and share any feedback you have on-list. We can pick up on these issues next week. Thanks, 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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