Exactly The IRT is meant to implement the output of the PDP. If people feel that something is “off” then it should be sent back to Council etc., - it is NOT for the IRT to make policy. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ https://blacknight.blog/ Intl. +353 (0) 59 9183072e I 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 I have sent this email at a time that is convenient for me. I do not expect you to respond to it outside of your usual working hours. From: Paul McGrady via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> Date: Tuesday, 10 December 2024 at 23:18 To: PPSAI IRT members, including observers <gdd-gnso-ppsai-impl@icann.org> Cc: Owen Smigelski <owen.smigelski@namecheap.com>, Paul McGrady <paul@elstermcgrady.com> Subject: [Gdd-gnso-ppsai-impl] Re: [Ext] Re: IRT Task 20241205: TQ.A: Provide feedback to on Draft Language for IRT Threshold Questions for GNSO Council Guidance. Due: 13 Dec 2024 [EXTERNAL EMAIL] Please use caution when opening attachments from unrecognised sources. Agree with Own and Reg. An IRT can’t change definitions in the Final Report and then implement what we wish the Final Report said. If the IRT believes a change to the Final Report is needed, that should be flagged as for Council to consider, not for the IRT to do on its own. Best, Paul From: Owen Smigelski via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> Sent: Tuesday, December 10, 2024 4:51 PM To: PPSAI IRT members, including observers <gdd-gnso-ppsai-impl@icann.org> Cc: Owen Smigelski <owen.smigelski@namecheap.com> Subject: [Gdd-gnso-ppsai-impl] Re: [Ext] Re: IRT Task 20241205: TQ.A: Provide feedback to on Draft Language for IRT Threshold Questions for GNSO Council Guidance. Due: 13 Dec 2024 Dennis, I agree with Reg, and will go even further: it is not within the remit of an IRT to make any changes to the Final Report and recommendations contained therein. There can be changes to the Final Report via the GNSO Council prior to adoption by the Board, but once approved by the Board, the IRT is "convened to assist staff in developing the implementation details for the policy to ensure that the implementation conforms to the intent of the policy recommendations” (quoting the GNSO Implementation Review Team (IRT) Principles & Guidelines). Changes to the Final Report, no matter how laudable, desirable, or logical, are completely outside of the scope of an IRT. Hard stop. To the extent the IRT can implement the recommendations with tweaks, those changes must align with the intent of the Final Report. Regards, Owen On Dec 10, 2024, at 14:36, Reg Levy via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> wrote: CAUTION: This email originated from outside the organization. Do not click links unless you can confirm the sender and know the content is safe. Dennis— I’m very hesitant to make any changes to Working Group Recommendation language as the Implementation Review Team. This is a job for the Working Group itself. However reasonable we find the changes to be, it sets a very concerning precedent for the Policy Development Process. Servus, Reg -- Reg Levy | Associate General Counsel – Domains +1 (323) 880-0831 Tucows #MakingTheInternetBetter UTC -8 On Dec 10, 2024, at 06:50, Dennis Chang <dennis.chang@icann.org<mailto:dennis.chang@icann.org>> wrote: 13 Dec 2024: IRT Task due Date. 19 Dec 2024: IRT Meeting Date Thanks Brian, Reg, and those making comments on the doc for TQ A. The topic is “Changes to Definition Language.” I’d like the IRT to consider beyond the Principled position of NO CHANGE at ALL. At the lowest level of change are the typos and grammar. Then word changes to reflect currency and clarity etc. We will need to create our own draft of the definition for our implementation. Could this be done without making any changes? For example, we can look at the work done by the 2016 IRT here. Final Report Definition P/P AA Definition "Privacy Service" means a service by which a Registered Name is registered to its beneficial user as the Registered Name Holder, but for which alternative, reliable contact information is provided by the privacy or proxy service provider for display of the Registered Name Holder's contact information in the Registration Data Service (WHOIS) or equivalent services. 1.24 “Privacy Service” means a service by which a Registered Name is registered to a Customer as the Registered Name Holder, but for which alternative, reliable contact information is provided by Provider for display in the Registration Data Directory Service rather than the Customer’s contact information in the Registration Data Directory Service. Please complete this task this week. Task# IRT Tasks (Homework) Due Date 20241205 TQ A. Provide feedback to on Draft Language for IRT Threshold Questions<https://docs.google.com/document/d/1jvVfgLtnqzcSarbL2UfeHQV_CykUbpv-DB_m5ZAg...> for GNSO Council Guidance. 13 Dec 2024 Thanks you! Dennis Chang From: BECKHAM Brian <brian.beckham@wipo.int<mailto:brian.beckham@wipo.int>> Date: Thursday, December 5, 2024 at 11:14 PM To: "PPSAI IRT members, including observers" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Dennis Chang <dennis.chang@icann.org<mailto:dennis.chang@icann.org>>, Reg Levy <rlevy@tucows.com<mailto:rlevy@tucows.com>> Subject: [Ext] RE: [Gdd-gnso-ppsai-impl] Re: IRT Task 20241205: TQ.A: Provide feedback to on Draft Language for IRT Threshold Questions for GNSO Council Guidance. Due: 13 Dec 2024 Hi Reg, Denis, all, I have added a comment in the document (I may be misunderstanding the relation here, but question 2 seems to be linked to question 1, and question 3 flows from that connection). Please can we also attribute the “concerns and inputs” to individuals to give them context. More fundamentally however, we seem to be missing the core question of whether subsequent events (e.g., GDPR and NIS2) somehow “overtake” the PPSAI recommendations such that they need to be reconsidered in whole or in part. Perhaps that is the gist of question 3, but it is not immediately clear to me if that is the case. I also think questions such as “would this require a new contract” or things to that effect are beyond the scope of this IRT and need not be asked here. Brian PS, it may only be me, but there still seems to be an issue with the mtg ICS invites. From: Reg Levy via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Sent: Thursday, December 5, 2024 10:56 PM To: PPSAI IRT members, including observers <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Dennis S. Chang <dennis.chang@icann.org<mailto:dennis.chang@icann.org>>; Reg Levy <rlevy@tucows.com<mailto:rlevy@tucows.com>> Subject: [Gdd-gnso-ppsai-impl] Re: IRT Task 20241205: TQ.A: Provide feedback to on Draft Language for IRT Threshold Questions for GNSO Council Guidance. Due: 13 Dec 2024 Dennis— Thank you! I’ve made some comments/edits to the document. There is no confusion about who the party responsible for the domain is—it is the registrant, in all cases. Where a service is affiliated with a registrar, the registrar has that information (and no other). Where a service is not affiliated with a registrar, that service is the registrant, whether or not it is apparent that a service exists. I’m pretty sure only the first question needs to be asked. The second two questions assume that the IRT can subvert the PDP by creating policy, which is the job of the working group, not of the IRT. Or of Council. Servus, Reg -- Reg Levy | Associate General Counsel – Domains +1 (323) 880-0831 Tucows #MakingTheInternetBetter UTC -8 On Dec 5, 2024, at 13:26, Dennis Chang via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> wrote: Dear IRT, Thanks to those communicating to us about the missing calendar invitation for today’s meeting. Per your suggestion, we cancelled today’s meeting, Our team here is double checking the tool and process on our side and will refresh the invitations going forward. I addition, we will take up on the offer by a some of you to help us test early to confirm the receipt of the calendar invitations on your side. Below is a task, I had intended to assign at the meeting today with explanation. We did not meet but it’s important that we don’t lose momentum, so we’ll go ahead and start this work via this email. 20241205 TQ A. Provide feedback to on Draft Language for IRT Threshold Questions[docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/1jvVfgLtnqzcSa...> for GNSO Council Guidance. 13 Dec 2024 When you open the document, you will see the “About” and “Instructions” which I hope will sufficiently explain your task. Please don’t hesitate to ask if you’d like further info. One note about the expand/collapse heading feature. You may see only the headers when you open the document. Please note “>” or “v” appeal when you place your curser over the Section header. You’ll see a message “Expand Heading” or “Collapse Heading” that you can click on to reveal or hide the content of the section. I find this new feature very helpful in orienting and organizing our work and I’d like us to use it. At this time of this email, you’ll see TQ A populated with the Draft Language for Questions to GNSO with the “Status: Initial draft review by IRT (5 Dec 2024)” TQ B below is also there being set up with the status “ICANN org drafting.” We plan to issue separate tasks for each TQ work to keep us together as we move forward. Thank you all for your continued support and contribution. Our staff here felt very badly about what happened with the calendar meeting invites but also remarked how cooperative, flexible, and understanding the IRT is working with us a team and even encouraging us. We indeed have the most excellent IRT. Thank you! Gratefully Yours, Dennis S. Chang GDD Programs Director Phone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org/> One World – One Internet _______________________________________________ Gdd-gnso-ppsai-impl mailing list -- gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> To unsubscribe send an email to gdd-gnso-ppsai-impl-leave@icann.org<mailto:gdd-gnso-ppsai-impl-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. 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