Materials, action items from 10 Oct Privacy/Proxy IRT call
Dear Colleagues, Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/10+October+2017. During the call, we discussed: The draft de-accredited Provider Transition Procedure, specifically in reference to how unresolved abuse complaints should be handled. In the updated (and attached) version, please refer to section 2.7, where a requirement for the terminating provider to transfer unresolved abuse complaints to the gaining provider upon termination has been added. This was a suggestion proposed by a member of the IRT. (Note: there is not a requirement for the gaining provider to process the abuse complaints on a shortened timeline.) Please let us know if you have any further feedback on the De-Accredited Provider Transition Procedure. The draft applicant guidebook/application: in the draft we discussed (version 4), the background check questions were changed to mirror the questions in the registrar accreditation application. Note to IRT: Please let us know if you believe this is in line with the WG’s recommendations. In the updated draft, we reverted to the language in the IP Framework (per feedback from some members of the IRT), and we added a question, per IRT feedback, asking applicants to inform ICANN if its principals/officers have previously been employed by an entity whose ICANN accreditation was involuntarily terminated by ICANN. Please see section 3.6 and section 6.10. A high-level overview of the changes to the updated PPAA draft: we will be discussing the updates in greater details in upcoming calls. For our call on Tuesday, October 17, we will be presenting the Data Escrow Specification (attached). You will have additional time to review and provide feedback on the Data Escrow Specification following the call. Following a summary of the Data Escrow Specification, we will be working through the updated PPAA. If there is anything in particular you would like to flag before the call, please respond via the list. Thank you! Best, Caitlin -- Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen@icann.org
Thanks for this, Caitlin. I am a bit puzzled by your second bullet point with regard to the revised Applicant Guide. First, I am not sure that anything in the IP disclosure framework relates directly to issues such as background checking. The minor changes to 6.10 were requested to conform to Recommendation 8 of the PDP WG Final Report, not to anything in the annex containing the IP disclosure framework. Second, just to clarify, do the background check questions now appearing as items 3.1 through 3.5 track the questions posed to registrar accreditation applicants? To the extent that questions contained in items 3.3 through 3.15 of the previous version of the application do not appear in the revised version, is that because these questions are not asked of applicants for registrar accreditation? Finally, thank you for including item 3.6 in the latest version, but may I propose the following slightly revised (and I hope slightly clearer) text: Has the Applicant and/or any of the entities mentioned in the answers to Section 3 previously had an ICANN accreditation involuntarily terminated, or have any of the persons mentioned in those answers previously been employed by an entity whose ICANN accreditation was involuntarily terminated? Thanks, and looking forward to your response. Steve Metalitz On behalf of Coalition for Online Accountability (COA) | www.onlineaccountability.net [image001] Steven J. Metalitz | Partner, through his professional corporation T: +1.202.355.7902 | met@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@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Caitlin Tubergen Sent: Sunday, October 15, 2017 2:23 PM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] Materials, action items from 10 Oct Privacy/Proxy IRT call Dear Colleagues, Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/10+October+2017. During the call, we discussed: * The draft de-accredited Provider Transition Procedure, specifically in reference to how unresolved abuse complaints should be handled. In the updated (and attached) version, please refer to section 2.7, where a requirement for the terminating provider to transfer unresolved abuse complaints to the gaining provider upon termination has been added. This was a suggestion proposed by a member of the IRT. (Note: there is not a requirement for the gaining provider to process the abuse complaints on a shortened timeline.) Please let us know if you have any further feedback on the De-Accredited Provider Transition Procedure. * The draft applicant guidebook/application: in the draft we discussed (version 4), the background check questions were changed to mirror the questions in the registrar accreditation application. Note to IRT: Please let us know if you believe this is in line with the WG’s recommendations. In the updated draft, we reverted to the language in the IP Framework (per feedback from some members of the IRT), and we added a question, per IRT feedback, asking applicants to inform ICANN if its principals/officers have previously been employed by an entity whose ICANN accreditation was involuntarily terminated by ICANN. Please see section 3.6 and section 6.10. * A high-level overview of the changes to the updated PPAA draft: we will be discussing the updates in greater details in upcoming calls. For our call on Tuesday, October 17, we will be presenting the Data Escrow Specification (attached). You will have additional time to review and provide feedback on the Data Escrow Specification following the call. Following a summary of the Data Escrow Specification, we will be working through the updated PPAA. If there is anything in particular you would like to flag before the call, please respond via the list. Thank you! Best, Caitlin -- Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org>
Hi Steve, Thank you for your message. You are correct, and I apologize for the mistake. The updates to the Applicant Guidebook conform to the Working Group’s Final Recommendations and the corresponding language in the PPAA, not the IP Framework. With respect to the Applicant Guidebook v5: yes, your understanding is correct. The questions now match exactly what is contained in the RAA Application Form, and yes, the removed questions are not asked of registrar applicants. Lastly, thank you for the proposed tweak to the draft question. I will incorporate into the updated Guidebook. Please let me know if you have any additional questions or concerns. Best regards, Caitlin From: <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of "Metalitz, Steven" <met@msk.com> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Monday, October 16, 2017 at 9:28 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 10 Oct Privacy/Proxy IRT call Thanks for this, Caitlin. I am a bit puzzled by your second bullet point with regard to the revised Applicant Guide. First, I am not sure that anything in the IP disclosure framework relates directly to issues such as background checking. The minor changes to 6.10 were requested to conform to Recommendation 8 of the PDP WG Final Report, not to anything in the annex containing the IP disclosure framework. Second, just to clarify, do the background check questions now appearing as items 3.1 through 3.5 track the questions posed to registrar accreditation applicants? To the extent that questions contained in items 3.3 through 3.15 of the previous version of the application do not appear in the revised version, is that because these questions are not asked of applicants for registrar accreditation? Finally, thank you for including item 3.6 in the latest version, but may I propose the following slightly revised (and I hope slightly clearer) text: Has the Applicant and/or any of the entities mentioned in the answers to Section 3 previously had an ICANN accreditation involuntarily terminated, or have any of the persons mentioned in those answers previously been employed by an entity whose ICANN accreditation was involuntarily terminated? Thanks, and looking forward to your response. Steve Metalitz On behalf of Coalition for Online Accountability (COA) | www.onlineaccountability.net Steven J. Metalitz | Partner, through his professional corporation T: +1.202.355.7902 | met@msk.com Mitchell Silberberg & Knupp LLP | 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@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Caitlin Tubergen Sent: Sunday, October 15, 2017 2:23 PM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] Materials, action items from 10 Oct Privacy/Proxy IRT call Dear Colleagues, Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/10+October+2017. During the call, we discussed: The draft de-accredited Provider Transition Procedure, specifically in reference to how unresolved abuse complaints should be handled. In the updated (and attached) version, please refer to section 2.7, where a requirement for the terminating provider to transfer unresolved abuse complaints to the gaining provider upon termination has been added. This was a suggestion proposed by a member of the IRT. (Note: there is not a requirement for the gaining provider to process the abuse complaints on a shortened timeline.) Please let us know if you have any further feedback on the De-Accredited Provider Transition Procedure. The draft applicant guidebook/application: in the draft we discussed (version 4), the background check questions were changed to mirror the questions in the registrar accreditation application. Note to IRT: Please let us know if you believe this is in line with the WG’s recommendations. In the updated draft, we reverted to the language in the IP Framework (per feedback from some members of the IRT), and we added a question, per IRT feedback, asking applicants to inform ICANN if its principals/officers have previously been employed by an entity whose ICANN accreditation was involuntarily terminated by ICANN. Please see section 3.6 and section 6.10. A high-level overview of the changes to the updated PPAA draft: we will be discussing the updates in greater details in upcoming calls. For our call on Tuesday, October 17, we will be presenting the Data Escrow Specification (attached). You will have additional time to review and provide feedback on the Data Escrow Specification following the call. Following a summary of the Data Escrow Specification, we will be working through the updated PPAA. If there is anything in particular you would like to flag before the call, please respond via the list. Thank you! Best, Caitlin -- Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen@icann.org
Hi Caitlin, et al, Two comments regarding the RDE spec. 3.1.5 This reads a bit funny. It's good that we MAY add additional CSV's, does this exclude a separate RDE deposit? What is the goal here? 3.16 Why not link to the RDE spec itself? At some point, I guess there will be changes, having a spec in one place makes it easier and less chance there is confusion. Just a practical point I guess. The agreement itself. Data Retention Spec. I am fine with adding such a specification, as long it does not violate applicable law, and this should be reflected in the language. I think we and the community should make sure we stop pushing ICANN ORG into a data controller situation. Waivers and all that have proven to be highly insufficient, a legal burden and in some cases contracted parties still have not required one. Thanks, Theo Geurts Caitlin Tubergen schreef op 2017-10-15 08:23 PM:
Dear Colleagues,
Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/10+October+2017.
During the call, we discussed:
* The draft de-accredited Provider Transition Procedure, specifically in reference to how unresolved abuse complaints should be handled. In the updated (and attached) version, please refer to section 2.7, where a requirement for the terminating provider to transfer unresolved abuse complaints to the gaining provider upon termination has been added. This was a suggestion proposed by a member of the IRT. (Note: there is not a requirement for the gaining provider to process the abuse complaints on a shortened timeline.) Please let us know if you have any further feedback on the De-Accredited Provider Transition Procedure.
* The draft applicant guidebook/application: in the draft we discussed (version 4), the background check questions were changed to mirror the questions in the registrar accreditation application. NOTE TO IRT: PLEASE LET US KNOW IF YOU BELIEVE THIS IS IN LINE WITH THE WG’S RECOMMENDATIONS. In the updated draft, we reverted to the language in the IP Framework (per feedback from some members of the IRT), and we added a question, per IRT feedback, asking applicants to inform ICANN if its principals/officers have previously been employed by an entity whose ICANN accreditation was involuntarily terminated by ICANN. Please see section 3.6 and section 6.10.
* A high-level overview of the changes to the updated PPAA draft: we will be discussing the updates in greater details in upcoming calls.
For our call on Tuesday, October 17, we will be presenting the DATA ESCROW SPECIFICATION (attached). You will have additional time to review and provide feedback on the Data Escrow Specification following the call. Following a summary of the Data Escrow Specification, we will be working through the updated PPAA. If there is anything in particular you would like to flag before the call, please respond via the list.
Thank you!
Best,
Caitlin
--
CAITLIN TUBERGEN
Registrar Services and Engagement Senior Manager
ICANN
12025 Waterfront Drive, Suite 300
Los Angeles, CA 90094
Office: +1 310 578 8666
Mobile: +1 310 699 5326
Email: caitlin.tubergen@icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
participants (3)
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Caitlin Tubergen -
gtheo -
Metalitz, Steven