Summary, action items from today's PP IRT call
Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency-IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission-on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today's meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format-on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields-on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today's call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate "total" numbers for requests for specific contacts, eliminate "publication" fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded "reasons for denial" fields. PP Applicant Guide 1. Issue 1: Shift to "rolling" application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many "essay" questions in favor of "checkbox" questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today's call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today's call, it appears that * If "action" is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>
Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Amy, Apologies, but I will not be available to attend the next 2 meetings. Thanks, Lisa Lisa Villeneuve domain compliance & advanced support team (DCAST) lvilleneuve@godaddy.com<mailto:lvilleneuve@godaddy.com> [cid:image001.png@01D2BCF0.267488B0]<http://www.godaddy.com/> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, February 22, 2018 4:55 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren't expected to review the draft prior to Tuesday's meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification (1) Issue 1: Report frequency-IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. (2) Issue 2: Report submission-on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today's meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. (3) Issue 3: Report format-on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. (4) Issue 4: Report fields-on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today's call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate "total" numbers for requests for specific contacts, eliminate "publication" fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded "reasons for denial" fields. PP Applicant Guide (1) Issue 1: Shift to "rolling" application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (2) Issue 2: Elimination of many "essay" questions in favor of "checkbox" questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (3) Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification (1) Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today's call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. (2) Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today's call, it appears that a. If "action" is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then b. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. c. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote:
Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues,
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best,
Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/.
*Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.*
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. 3. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.*
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@icann.org<mailto:amy.bivins@icann.org>
www.icann.org<http://www.icann.org>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Apologies for my somewhat knee-jerk reaction. However, personally speaking, I cannot keep up with this IRT (and other projects) anymore. I am aware I was one of the persons who agreed to set a rigorous timeline, but I did not take into account the GDPR madness, which is not exclusive to ICANN but is somewhat mirrored on a ccTLD level and tons of other contracts we have with vendors outside the DNS. Answer times, review deadlines, it has become too much, and I think bi-weekly meetings are not a bad idea here. Thanks, Theo On 22-2-2018 22:24, Amy Bivins wrote:
Hi All,
We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March.
As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled.
Best, Amy
On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl <mailto:gtheo@xs4all.nl>> wrote:
Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here.
The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here.
Theo
On 22-2-2018 21:51, Sara Bockey wrote:
Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues,
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best,
Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/.
*Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.*
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. 3. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.*
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@icann.org<mailto:amy.bivins@icann.org>
www.icann.org<http://www.icann.org>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Amy, can you confirm that staff still plans to circulate the revised version of the PPAA by early next week, as stated during our call, other than the LE framework and reporting specification, which are the only two open PPAA issues listed below? I believe staff was also going to provide on the same timeline the cost recovery data requested on the call to justify the proposed accreditation fees. I agree that IRT participants face a lot of bandwidth challenges right now but hopefully we can minimize delays by sticking to the staff timeline commitments noted above. Please advise. Thanks. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, February 22, 2018 4:24 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week's IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday's call and I think it's safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy(tm) sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren't expected to review the draft prior to Tuesday's meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/<https://participate.icann.org/p39onhjd1g1/>. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency-IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission-on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today's meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format-on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields-on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today's call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate "total" numbers for requests for specific contacts, eliminate "publication" fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded "reasons for denial" fields. PP Applicant Guide 1. Issue 1: Shift to "rolling" application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many "essay" questions in favor of "checkbox" questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today's call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today's call, it appears that * If "action" is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl>
Steve, Amy will address your PPAA inquiry when she returns to the office on Monday. I am working with finance to have them put forth the cost recovery information and hopefully present it to the IRT during our March 6, 2018 call. I will keep the IRT posted on this item. Jennifer On Feb 23, 2018, at 10:23 AM, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: Amy, can you confirm that staff still plans to circulate the revised version of the PPAA by early next week, as stated during our call, other than the LE framework and reporting specification, which are the only two open PPAA issues listed below? I believe staff was also going to provide on the same timeline the cost recovery data requested on the call to justify the proposed accreditation fees. I agree that IRT participants face a lot of bandwidth challenges right now but hopefully we can minimize delays by sticking to the staff timeline commitments noted above. Please advise. Thanks. Steve Metalitz <image001.gif> Steven J. Metalitz | Partner, through his professional corporation T: 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, February 22, 2018 4:24 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Steve and all, Yes, we will distribute the updated PPAA draft early next week. This will include updates based on all of the IRT's feedback to date other than the remaining LEA and reporting issues (and I'll try to mark where text might need to be updated based on the input thus far on those final remaining issues). I'll send both a clean and a redline version (against the last version that was distributed 6 December). I'll also annotate (with references to the Final Report) and include comments about why edits were made (or not made) in the redline version. If there's anything else I can do to make the document more easy to review please don't hesitate to ask. Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Metalitz, Steven Sent: Friday, February 23, 2018 10:23 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Amy, can you confirm that staff still plans to circulate the revised version of the PPAA by early next week, as stated during our call, other than the LE framework and reporting specification, which are the only two open PPAA issues listed below? I believe staff was also going to provide on the same timeline the cost recovery data requested on the call to justify the proposed accreditation fees. I agree that IRT participants face a lot of bandwidth challenges right now but hopefully we can minimize delays by sticking to the staff timeline commitments noted above. Please advise. Thanks. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, February 22, 2018 4:24 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week's IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday's call and I think it's safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy(tm) sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren't expected to review the draft prior to Tuesday's meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency-IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission-on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today's meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format-on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields-on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today's call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate "total" numbers for requests for specific contacts, eliminate "publication" fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded "reasons for denial" fields. PP Applicant Guide 1. Issue 1: Shift to "rolling" application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many "essay" questions in favor of "checkbox" questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today's call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today's call, it appears that * If "action" is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Thanks Amy. Sent with BlackBerry Work (www.blackberry.com) From: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Date: Friday, Feb 23, 2018, 8:51 PM To: gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi Steve and all, Yes, we will distribute the updated PPAA draft early next week. This will include updates based on all of the IRT’s feedback to date other than the remaining LEA and reporting issues (and I’ll try to mark where text might need to be updated based on the input thus far on those final remaining issues). I’ll send both a clean and a redline version (against the last version that was distributed 6 December). I’ll also annotate (with references to the Final Report) and include comments about why edits were made (or not made) in the redline version. If there’s anything else I can do to make the document more easy to review please don’t hesitate to ask. Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Metalitz, Steven Sent: Friday, February 23, 2018 10:23 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Amy, can you confirm that staff still plans to circulate the revised version of the PPAA by early next week, as stated during our call, other than the LE framework and reporting specification, which are the only two open PPAA issues listed below? I believe staff was also going to provide on the same timeline the cost recovery data requested on the call to justify the proposed accreditation fees. I agree that IRT participants face a lot of bandwidth challenges right now but hopefully we can minimize delays by sticking to the staff timeline commitments noted above. Please advise. Thanks. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, February 22, 2018 4:24 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/<https://participate.icann.org/p39onhjd1g1/>. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl>
Hi Amy- For the IRT meeting in Puerto Rico, could Staff prepare slides summarizing the key issues that are reflected in the draft agreement? I think that will be helpful to those who haven’t been tracking the progress of the IRT as closely. Thanks, Margie From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 1:25 PM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/<https://urldefense.proofpoint.com/v2/url?u=https-3A__participate.icann.org_p39onhjd1g1_&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=A9WF61gaF0ZG_9pkIvQ3rH-6ENC28t5tpO8gEVgQSEQ&e=>. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMF-g&c...> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=>
Hi Margie, Absolutely. I think we can probably go ahead and provide those this week, before ICANN61, to aid the IRT’s final review of the document before public comment (instead of waiting until ICANN61) if that’s helpful! Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Margie Milam Sent: Tuesday, February 27, 2018 10:03 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi Amy- For the IRT meeting in Puerto Rico, could Staff prepare slides summarizing the key issues that are reflected in the draft agreement? I think that will be helpful to those who haven’t been tracking the progress of the IRT as closely. Thanks, Margie From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Thursday, February 22, 2018 at 1:25 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/<https://urldefense.proofpoint.com/v2/url?u=https-3A__participate.icann.org_p39onhjd1g1_&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=A9WF61gaF0ZG_9pkIvQ3rH-6ENC28t5tpO8gEVgQSEQ&e=>. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMF-g&c...> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=>
Yes- that would be very helpful. Thanks Amy! Margie From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Tuesday, February 27, 2018 at 7:30 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi Margie, Absolutely. I think we can probably go ahead and provide those this week, before ICANN61, to aid the IRT’s final review of the document before public comment (instead of waiting until ICANN61) if that’s helpful! Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Margie Milam Sent: Tuesday, February 27, 2018 10:03 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi Amy- For the IRT meeting in Puerto Rico, could Staff prepare slides summarizing the key issues that are reflected in the draft agreement? I think that will be helpful to those who haven’t been tracking the progress of the IRT as closely. Thanks, Margie From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Thursday, February 22, 2018 at 1:25 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/<https://urldefense.proofpoint.com/v2/url?u=https-3A__participate.icann.org_p39onhjd1g1_&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=A9WF61gaF0ZG_9pkIvQ3rH-6ENC28t5tpO8gEVgQSEQ&e=>. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMF-g&c...> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gdd-2Dgnso-2Dppsai-2Dimpl&d=DwMF-g&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=Y88L13zZbA8-6Uqcold5uuWDGpyOt29s27QUev4O7sM&s=W0iIklLrIcGXFAZV0W_3IsFP7X2qUjC5rzVXfADAUis&e=>
As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Amy Bivins <amy.bivins@icann.org> Date: Thursday, February 22, 2018 at 2:24 PM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Cc: Sara Bockey <sbockey@godaddy.com> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
I agree 100% with all of these points Regards Michele Mr Michele Neylon https://www.blacknight.com/ https://michele.blog Intl. +353 (0)59 9183072 Sent from mobile so usual disclaimers about typos etc apply On 2 Mar 2018, at 13:58, Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> wrote: As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Date: Thursday, February 22, 2018 at 2:24 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
+1 on all of these points. -Greg From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Michele Neylon - Blacknight Sent: Friday, March 02, 2018 11:03 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call I agree 100% with all of these points Regards Michele Mr Michele Neylon https://www.blacknight.com/ https://michele.blog Intl. +353 (0)59 9183072 Sent from mobile so usual disclaimers about typos etc apply On 2 Mar 2018, at 13:58, Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> wrote: As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that 1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Date: Thursday, February 22, 2018 at 2:24 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification (1) Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. (2) Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. (3) Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. (4) Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide (1) Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (2) Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (3) Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification (1) Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. (2) Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that a. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then b. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. c. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Agree to the feedback raised also. Regards, Eric *Eric Rokobauer* Sr. Registrar Compliance Manager | Endurance International Group 10 Corporate Drive, Suite 300, Burlington MA 01803 T - 781.852.3445 <%28781%29%20852-3445> E - eric.rokobauer@endurance.com On Mar 2, 2018 2:41 PM, "DiBiase, Gregory via Gdd-gnso-ppsai-impl" < gdd-gnso-ppsai-impl@icann.org> wrote: +1 on all of these points. -Greg *From:* Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Michele Neylon - Blacknight *Sent:* Friday, March 02, 2018 11:03 AM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call I agree 100% with all of these points Regards Michele Mr Michele Neylon https://www.blacknight.com/ https://michele.blog Intl. +353 (0)59 9183072 <+353%2059%20918%203072> Sent from mobile so usual disclaimers about typos etc apply On 2 Mar 2018, at 13:58, Sara Bockey <sbockey@godaddy.com> wrote: As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response. *Monthly Reporting Specification* 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. *PP Applicant Guide* 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. *LEA Disclosure Framework Specification* 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that 1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. * I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. *sara bockey* *sr. policy manager | **Go**Daddy™* *sbockey@godaddy.com <sbockey@godaddy.com> 480-366-3616 <(480)%20366-3616>* *skype: sbockey* *This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.* *From: *Amy Bivins <amy.bivins@icann.org> *Date: *Thursday, February 22, 2018 at 2:24 PM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Cc: *Sara Bockey <sbockey@godaddy.com> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara *sara bockey* *sr. policy manager | **Go**Daddy™* *sbockey@godaddy.com <sbockey@godaddy.com> 480-366-3616 <(480)%20366-3616>* *skype: sbockey* *This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.* *From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> <amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. *Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.* *Monthly Reporting Specification* (1) Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. (2) Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. (3) Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. (4) Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. *PP Applicant Guide* (1) Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (2) Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (3) Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). *LEA Disclosure Framework Specification* (1) Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. (2) Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that a. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then b. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. c. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.* 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 <(202)%20249-7551> Fax: +1 (202) 789-0104 <(202)%20789-0104> Email: amy.bivins@icann.org www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Excellent points. Full support! Best, Volker Am 02.03.2018 um 21:18 schrieb Eric Rokobauer:
Agree to the feedback raised also.
Regards, Eric
*/Eric Rokobauer/* Sr. Registrar Compliance Manager | Endurance International Group 10 Corporate Drive, Suite 300, Burlington MA 01803 T - 781.852.3445 <tel:%28781%29%20852-3445> E - eric.rokobauer@endurance.com <mailto:eric.rokobauer@endurance.com>
On Mar 2, 2018 2:41 PM, "DiBiase, Gregory via Gdd-gnso-ppsai-impl" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> wrote:
+1 on all of these points.
-Greg
*From:* Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] *On Behalf Of *Michele Neylon - Blacknight *Sent:* Friday, March 02, 2018 11:03 AM *To:* gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>
*Subject:* Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
I agree 100% with all of these points
Regards
Michele
Mr Michele Neylon
Intl. +353 (0)59 9183072 <tel:+353%2059%20918%203072>
Sent from mobile so usual disclaimers about typos etc apply
On 2 Mar 2018, at 13:58, Sara Bockey <sbockey@godaddy.com <mailto:sbockey@godaddy.com>> wrote:
As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response.
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred.
2.Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point.
The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email.
For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so.
3.Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective.
4.Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach.
No issue with this change.
2.Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach.
No issue with this change.
3.Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks.
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week.
2.Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1.If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then
2.The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification.
No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language:
Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law.
3.*IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. *
I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure.
What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control.
Again, I would like following language considered:
Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law.
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616 <tel:%28480%29%20366-3616>*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> *Date: *Thursday, February 22, 2018 at 2:24 PM *To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Cc: *Sara Bockey <sbockey@godaddy.com <mailto:sbockey@godaddy.com>> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Hi All,
We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March.
As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled.
Best,
Amy
On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl <mailto:gtheo@xs4all.nl>> wrote:
Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here.
The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here.
Theo
On 22-2-2018 21:51, Sara Bockey wrote:
Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616 <tel:%28480%29%20366-3616>*
*skype: sbockey*
//
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*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> <mailto:amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <mailto:gdd-gnso-ppsai-impl@icann.org> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <mailto:gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues,
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best,
Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/ <https://participate.icann.org/p39onhjd1g1/>.
*Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.*
*Monthly Reporting Specification*
(1)Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft.
(2)Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point.
(3)Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
(4)Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
(1)Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach.
(2)Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach.
(3)Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
*LEA Disclosure Framework Specification*
(1)Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week.
(2)Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
a.If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then
b.The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification.
c.*IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.*
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 <tel:%28202%29%20249-7551>
Fax: +1 (202) 789-0104 <tel:%28202%29%20789-0104>
Email: amy.bivins@icann.org <mailto:amy.bivins@icann.org>
www.icann.org <http://www.icann.org>
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-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
Dear Colleagues, Unfortunately, the finance team will not be available to join our meeting today to present the data associated with the PP program fee schedule. However, they have committed to present in person during the IRT mtg in Puerto Rico on Sunday March 11, 2018 at 6:30 PM. If the meantime, please let me know if you have any questions. Thank you, Jennifer Gore
Hi Jenn, Can you please confirm that the slides and their "reasoning" is sent out via this list please - as I am not attending in person, nor remotely as thats gone midnight UK time. Kind regards, Chris From: "Jennifer Gore" <jennifer.gore@icann.org> To: gdd-gnso-ppsai-impl@icann.org Sent: Tuesday, 6 March, 2018 12:28:37 Subject: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call Dear Colleagues, Unfortunately, the finance team will not be available to join our meeting today to present the data associated with the PP program fee schedule. However, they have committed to present in person during the IRT mtg in Puerto Rico on Sunday March 11, 2018 at 6:30 PM. If the meantime, please let me know if you have any questions. Thank you, Jennifer Gore _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Chris and all, Yes. I can confirm the finance team's deliverables will contain description of services rendered by application and ongoing maintenance of the program along with reasoning associated with the fee schedule. My apologies for the delay. Thank you, Jennifer On Mar 6, 2018, at 7:40 AM, Chris Pelling <chris@netearth.net<mailto:chris@netearth.net>> wrote: Hi Jenn, Can you please confirm that the slides and their "reasoning" is sent out via this list please - as I am not attending in person, nor remotely as thats gone midnight UK time. Kind regards, Chris ________________________________ From: "Jennifer Gore" <jennifer.gore@icann.org<mailto:jennifer.gore@icann.org>> To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Sent: Tuesday, 6 March, 2018 12:28:37 Subject: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call Dear Colleagues, Unfortunately, the finance team will not be available to join our meeting today to present the data associated with the PP program fee schedule. However, they have committed to present in person during the IRT mtg in Puerto Rico on Sunday March 11, 2018 at 6:30 PM. If the meantime, please let me know if you have any questions. Thank you, Jennifer Gore _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
+1 on all ponts mentioned. Kind regards, Chris From: "Michele Neylon" <michele@blacknight.com> To: gdd-gnso-ppsai-impl@icann.org Sent: Friday, 2 March, 2018 19:03:16 Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call I agree 100% with all of these points Regards Michele Mr Michele Neylon https://www.blacknight.com/ https://michele.blog Intl. +353 (0)59 9183072 Sent from mobile so usual disclaimers about typos etc apply On 2 Mar 2018, at 13:58, Sara Bockey < sbockey@godaddy.com > wrote: As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that 1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. sara bockey sr. policy manager | Go Daddy ™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Amy Bivins < amy.bivins@icann.org > Date: Thursday, February 22, 2018 at 2:24 PM To: " gdd-gnso-ppsai-impl@icann.org " < gdd-gnso-ppsai-impl@icann.org > Cc: Sara Bockey < sbockey@godaddy.com > Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts < gtheo@xs4all.nl > wrote: BQ_BEGIN Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: BQ_BEGIN Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | Go Daddy ™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins < amy.bivins@icann.org > wrote: BQ_BEGIN Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/ . Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that 1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org www.icann.org BQ_BEGIN _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END BQ_END BQ_BEGIN _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END BQ_END BQ_BEGIN _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Agreed with all points, except. 1 Since we seem to be reporting for the reporting, annual. A good weekend, Theo On 2-3-2018 19:57, Sara Bockey wrote:
As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response.
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred.
2.Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point.
The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email.
For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so.
3.Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective.
4.Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach.
No issue with this change.
2.Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach.
No issue with this change.
3.Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks.
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week.
2.Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then
2.The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification.
No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language:
Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law.
3.*IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. *
I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure.
What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control.
Again, I would like following language considered:
Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law.
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Amy Bivins <amy.bivins@icann.org> *Date: *Thursday, February 22, 2018 at 2:24 PM *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Cc: *Sara Bockey <sbockey@godaddy.com> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Hi All,
We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March.
As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled.
Best,
Amy
On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl <mailto:gtheo@xs4all.nl>> wrote:
Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here.
The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here.
Theo
On 22-2-2018 21:51, Sara Bockey wrote:
Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> <mailto:amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <mailto:gdd-gnso-ppsai-impl@icann.org> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org" <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <mailto:gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues,
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best,
Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/.
*Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.*
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. 3. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.*
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@icann.org<mailto:amy.bivins@icann.org>
www.icann.org<http://www.icann.org>
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I agree with all these points too but I object to using ‘best efforts’ as from a legal perspective this implies we will do anything (and I mean anything) to respond. As Sara said, we will do our best to respond in a dire situation but I am not comfortable with this contractually. I would prefer we say endeavour instead of best efforts. Many thanks Lindsay Lindsay Hamilton-Reid Senior Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid@1and1.co.uk<mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk<http://www.fasthosts.co.uk/> www.1and1.co.uk<http://www.1and1.co.uk/> [fh-1and1] © 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. If you are not the intended recipient, you should not disclose, copy or use any part of it - please delete all copies immediately and notify 1&1 on 0844 335 1211 or Fasthosts on 0333 0142 700. Any statements, opinions or information in this message are provided by the author, not on behalf of 1&1 and/or Fasthosts, unless subsequently confirmed by an individual who is authorised to represent 1&1 and/or Fasthosts. [linkedin]<http://www.linkedin.com/company/fasthosts-internet-ltd>[twitter]<https://twitter.com/Fasthosts>[facebook]<https://www.facebook.com/fasthostsinternet>[gplus]<https://plus.google.com/u/0/b/107582097021398424605/+fasthosts/posts>[blog]<http://blogs.fasthosts.co.uk/>[youtube]<http://www.youtube.com/user/Fasthostsinternet> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: 02 March 2018 18:58 To: Amy Bivins <amy.bivins@icann.org>; gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that 1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Date: Thursday, February 22, 2018 at 2:24 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification (1) Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. (2) Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. (3) Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. (4) Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide (1) Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (2) Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. (3) Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification (1) Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. (2) Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that a. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then b. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. c. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Thanks, Lindsay! It appears that we are seeing fairly broad agreement among the registrar members of the group on this proposed language, with the exception, potentially, of the “best efforts” language. Would the registrar members of the IRT like to continue discussing this topic and propose some language for discussion during the session at ICANN61? Best, Amy From: Lindsay Hamilton-Reid [mailto:Lindsay.Hamilton-Reid@fasthosts.com] Sent: Monday, March 5, 2018 3:53 AM To: gdd-gnso-ppsai-impl@icann.org; Amy Bivins <amy.bivins@icann.org> Subject: [Ext] RE: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call I agree with all these points too but I object to using ‘best efforts’ as from a legal perspective this implies we will do anything (and I mean anything) to respond. As Sara said, we will do our best to respond in a dire situation but I am not comfortable with this contractually. I would prefer we say endeavour instead of best efforts. Many thanks Lindsay Lindsay Hamilton-Reid Senior Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid@1and1.co.uk<mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk[fasthosts.co.uk]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.fasthosts.co.uk_&d=D...> www.1and1.co.uk[1and1.co.uk]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.1and1.co.uk_&d=DwMGa...> [fh-1and1] © 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. 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For ease of reading I’m restating the question and then providing my response. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email. For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks. LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. 3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure. What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Date: Thursday, February 22, 2018 at 2:24 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Hi All, We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March. As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled. Best, Amy On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org[icann.org]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMGaQ&c...> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Amy, Hope you’re well. I’m mindful that I no longer have a formal role on this IRT as regards the LEA framework, however I have some thoughts on this particular issue in my personal capacity, which I’d like to share with the list if appropriate. Am I still listed as a member of the IRT? Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists@nickshorey.com Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin Web: www.nickshorey.com
On 5 Mar 2018, at 15:15, Amy Bivins <amy.bivins@icann.org> wrote:
Thanks, Lindsay!
It appears that we are seeing fairly broad agreement among the registrar members of the group on this proposed language, with the exception, potentially, of the “best efforts” language. Would the registrar members of the IRT like to continue discussing this topic and propose some language for discussion during the session at ICANN61?
Best, Amy
From: Lindsay Hamilton-Reid [mailto:Lindsay.Hamilton-Reid@fasthosts.com <mailto:Lindsay.Hamilton-Reid@fasthosts.com>] Sent: Monday, March 5, 2018 3:53 AM To: gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>; Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> Subject: [Ext] RE: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
I agree with all these points too but I object to using ‘best efforts’ as from a legal perspective this implies we will do anything (and I mean anything) to respond. As Sara said, we will do our best to respond in a dire situation but I am not comfortable with this contractually. I would prefer we say endeavour instead of best efforts.
Many thanks
Lindsay
Lindsay Hamilton-Reid Senior Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid@1and1.co.uk <mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk[fasthosts.co.uk] <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.fasthosts.co.uk_&d=D...> www.1and1.co.uk[1and1.co.uk] <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.1and1.co.uk_&d=DwMGa...> <image001.jpg> © 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. If you are not the intended recipient, you should not disclose, copy or use any part of it - please delete all copies immediately and notify 1&1 on 0844 335 1211 or Fasthosts on 0333 0142 700. Any statements, opinions or information in this message are provided by the author, not on behalf of 1&1 and/or Fasthosts, unless subsequently confirmed by an individual who is authorised to represent 1&1 and/or Fasthosts. <image002.jpg>[linkedin.com] <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_company_fasthosts-2Dinternet-2Dltd&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgtdWrvLyZDu0mXuk&m=yL8l4Y1wN2j5hnXL-llev8mhy9a8WRlFYW1VWdBF6SA&s=uvHO2TFdmjQxBhp7ah_dYP4P-dU-cGvulpnmt7ynZVY&e=><image003.jpg>[twitter.com] <https://urldefense.proofpoint.com/v2/url?u=https-3A__twitter.com_Fasthosts&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgtdWrvLyZDu0mXuk&m=yL8l4Y1wN2j5hnXL-llev8mhy9a8WRlFYW1VWdBF6SA&s=4_ZdTLntBxvtyO5sc_0l5UGHJXH05VnUaWM7fbMOp5s&e=><image004.jpg>[facebook.com] <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.facebook.com_fasthostsinternet&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgtdWrvLyZDu0mXuk&m=yL8l4Y1wN2j5hnXL-llev8mhy9a8WRlFYW1VWdBF6SA&s=D4sZ6XGAHj1nh6p6XVpjYa_LGy_6awP7HQ78x4ryiBQ&e=><image005.jpg>[plus.google.com] <https://urldefense.proofpoint.com/v2/url?u=https-3A__plus.google.com_u_0_b_107582097021398424605_-2Bfasthosts_posts&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgtdWrvLyZDu0mXuk&m=yL8l4Y1wN2j5hnXL-llev8mhy9a8WRlFYW1VWdBF6SA&s=fTYt--51QdZGNuZaJxCvnp3PV-MmpPeLsbk0H81-rhA&e=><image006.jpg>[blogs.fasthosts.co.uk] <https://urldefense.proofpoint.com/v2/url?u=http-3A__blogs.fasthosts.co.uk_&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgtdWrvLyZDu0mXuk&m=yL8l4Y1wN2j5hnXL-llev8mhy9a8WRlFYW1VWdBF6SA&s=6lHfmGgIXTCjltqa-GXkIUJ3ywtQJJZtTrhk4qrLTsg&e=><image007.jpg>[youtube.com] <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.youtube.com_user_Fas...>
From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Sara Bockey Sent: 02 March 2018 18:58 To: Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>>; gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
As requested, I’m providing feedback to the bulleted items at the bottom of this thread. For ease of reading I’m restating the question and then providing my response.
Monthly Reporting Specification Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Reports could be submitted quarterly at maximum. Bi-annual or annual would be preferred.
2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. The reporting spec is overly burdensome. Reporting must be simple enough for smaller companies to use without necessitating technical implementation. Companies should not have to spend significant amounts of money creating a system to support this specification. Reporting can and should therefore be permissible by form of a pre-formatted email.
For issues 1 and 2, let's start simple and basic. Allow the Provider to fill out a sheet and email it to a designated address. If after submitting the first few reports it’s clear that we need to re-evaluate the process, we can come back and do so.
3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Again, the requirements set forth in the current spec are too complicated. Simple is what is needed. The reports should only focus on the number of requests, and the actions taken on a global perspective.
4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
PP Applicant Guide Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change.
2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. No issue with this change.
3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). Current proposed fees are not acceptable, and we look forward to ICANN providing its justification. Fees must be justified and reasonable considering the business models and volumes of service providers that are to be accredited. The new gTLD application fees were also meant to be cost-neutral, based on cost recovery, and that resulted in a huge surplus. Also, significant savings can be achieved in reducing or eliminating the requirements for background checks.
LEA Disclosure Framework Specification Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week.
2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then
2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. No. That is an incorrect presumption. The 24-hour response time is still overly strict. I propose the following language: Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law.
3. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. I oppose the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. As previously stated, the 24-hour requirement is overly strict. This does not mean we will not try to move heaven and earth to assist LEA in a dire situation, but having it baked into a contract is a recipe for failure.
What Section 4.2.2 fails to recognize are extraordinary circumstances that could arise outside of the 3 reasons list. There could be a DDOS attack that cripples the Provider’s systems, or there could be a flu epidemic that leaves the Provider short staffed and with a backlog, just to name a few. The point being that very valid circumstances could arise outside of the reasons listed in 4.2.2 and outside a Provider’s control. Again, I would like following language considered:
Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law.
sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey
This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.
From: Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> Date: Thursday, February 22, 2018 at 2:24 PM To: "gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Sara Bockey <sbockey@godaddy.com <mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Hi All,
We can provide an additional week for IRT input on the items below. Please send any feedback on these topics to the list by the end of next week, 2 March.
As this will impact our ability to finalize the PPAA draft, next week’s IRT meeting will be canceled.
Best, Amy
On Feb 22, 2018, at 4:04 PM, theo geurts <gtheo@xs4all.nl <mailto:gtheo@xs4all.nl>> wrote:
Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here.
The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here.
Theo
On 22-2-2018 21:51, Sara Bockey wrote: Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey
This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.
From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins<amy.bivins@icann.org> <mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org" <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org> <mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues, <>
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best, Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki,https://participate.icann.org/p39onhjd1g1/ <https://participate.icann.org/p39onhjd1g1/>.
Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.
Monthly Reporting Specification Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
PP Applicant Guide Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
LEA Disclosure Framework Specification Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org <mailto:amy.bivins@icann.org> www.icann.org[icann.org] <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMGaQ&c...>
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I saw that on the schedule as well. I don’t know who thinks that those kind of hours are “normal” or “acceptable”, but I can’t see many people turning up for a meeting at that time after a full day of meetings. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ https://blacknight.blog/ https://ceo.hosting/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 ------------------------------- 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@icann.org> on behalf of theo geurts <gtheo@xs4all.nl> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday 22 February 2018 at 22:04 To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org>, Sara Bockey <sbockey@godaddy.com> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Agreed, the time we have to invest due to GDPR is weighing heavy on contracted parties and I am pretty sure no one expected we had to deep dive so hard into all these models and many many calls. Did the T&T even reach quorum yesterday? The last meeting it was me and Roger Carney as the only attendees. IRT's and WG's are suffering due to the GDPR, I think we are asking too much of the volunteer workforce here. The meeting in PR, 18:30 till 20:00 for the PPSAI, I cannot believe that. My first meeting starts at 8 am that day. Is it normal ICANN staff works from 8 am to 8 pm? I do not find it normal as we do not get paid. This is getting close to slave labor here. Theo On 22-2-2018 21:51, Sara Bockey wrote: Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org><mailto:amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Amy, Additionally, it would be helpful if you could provide a bit more info re Report Model, Issue 2. Does ICANN’s reporting interface allow for files to be uploaded or is it a fill in the blank interface? If uploads are allowed, is there a limit on file size, type of file that can be used? Any additional information on how this interface works or is intended to work that would be very helpful. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Sara Bockey <sbockey@godaddy.com> Date: Thursday, February 22, 2018 at 1:51 PM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Sara, Sorry for the delay—needed to consult with the tech team on this one. ICANN’s Registration Reporting Interfaces (RRI) is a RESTful API that uses HTTP basic authentication (RRI does not provide a graphic interface). This API is currently used by both Registry Operators and Data Escrow Agents for their daily and monthly reporting, and soon to incorporate Registrar Data Escrow Agents as well. For the reports, the contents to upload are described in the PPSP reporting specification (CSV formatted text files in UTF-8 encoding). The draft reporting specification for Privacy/Proxy is attached. We’ve updated this to account for the discussion on the call this week that seemed to prefer quarterly rather than monthly reporting, though we can revisit that if we get more input on that specific point. For reference, the latest public version of for the Registries is available at https://tools.ietf.org/html/draft-lozano-icann-registry-interfaces Thanks, and have a great weekend, all! Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Thursday, February 22, 2018 4:33 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Amy, Additionally, it would be helpful if you could provide a bit more info re Report Model, Issue 2. Does ICANN’s reporting interface allow for files to be uploaded or is it a fill in the blank interface? If uploads are allowed, is there a limit on file size, type of file that can be used? Any additional information on how this interface works or is intended to work that would be very helpful. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Sara Bockey <sbockey@godaddy.com<mailto:sbockey@godaddy.com>> Date: Thursday, February 22, 2018 at 1:51 PM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Amy, As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues. As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work. Thanks, Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 1. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
So for most of us this will be a manual process and we need an API to send ICANN the reports? This means we need to integrate the API into a backend and front end solution, ie from spreadsheet to API. Perhaps some bigger registrars might want to weigh in on this, how compatible is this with your current abuse desk software? I do expect some push back from the NCUC and the NCSG here though. It seems providing privacy is only available for "premium club members". Is this what the WG envisioned?? Theo On 24-2-2018 02:44, Amy Bivins wrote:
Hi Sara,
Sorry for the delay—needed to consult with the tech team on this one.
ICANN’s Registration Reporting Interfaces (RRI) is a RESTful API that uses HTTP basic authentication (RRI does not provide a graphic interface). This API is currently used by both Registry Operators and Data Escrow Agents for their daily and monthly reporting, and soon to incorporate Registrar Data Escrow Agents as well.
For the reports, the contents to upload are described in the PPSP reporting specification (CSV formatted text files in UTF-8 encoding).
The draft reporting specification for Privacy/Proxy is attached. We’ve updated this to account for the discussion on the call this week that seemed to prefer quarterly rather than monthly reporting, though we can revisit that if we get more input on that specific point. For reference, the latest public version of for the Registries is available at https://tools.ietf.org/html/draft-lozano-icann-registry-interfaces
Thanks, and have a great weekend, all!
Amy
*From:* Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Sara Bockey *Sent:* Thursday, February 22, 2018 4:33 PM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Amy,
Additionally, it would be helpful if you could provide a bit more info re *Report Model, Issue 2*. Does ICANN’s reporting interface allow for files to be uploaded or is it a fill in the blank interface? If uploads are allowed, is there a limit on file size, type of file that can be used? Any additional information on how this interface works or is intended to work that would be very helpful.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Sara Bockey <sbockey@godaddy.com <mailto:sbockey@godaddy.com>> *Date: *Thursday, February 22, 2018 at 1:51 PM *To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues,
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best,
Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/.
*Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.*
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. 3. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.*
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@icann.org<mailto:amy.bivins@icann.org>
www.icann.org<http://www.icann.org>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
This proposal is nonsense. Just let us send ICANN an annual email and be done with it. It completely fulfils the WG requirement and does not require any implementation. Let us go the soft-touch route whereever we can. Volker Am 24.02.2018 um 22:12 schrieb theo geurts:
So for most of us this will be a manual process and we need an API to send ICANN the reports?
This means we need to integrate the API into a backend and front end solution, ie from spreadsheet to API. Perhaps some bigger registrars might want to weigh in on this, how compatible is this with your current abuse desk software?
I do expect some push back from the NCUC and the NCSG here though. It seems providing privacy is only available for "premium club members". Is this what the WG envisioned??
Theo
On 24-2-2018 02:44, Amy Bivins wrote:
Hi Sara,
Sorry for the delay—needed to consult with the tech team on this one.
ICANN’s Registration Reporting Interfaces (RRI) is a RESTful API that uses HTTP basic authentication (RRI does not provide a graphic interface). This API is currently used by both Registry Operators and Data Escrow Agents for their daily and monthly reporting, and soon to incorporate Registrar Data Escrow Agents as well.
For the reports, the contents to upload are described in the PPSP reporting specification (CSV formatted text files in UTF-8 encoding).
The draft reporting specification for Privacy/Proxy is attached. We’ve updated this to account for the discussion on the call this week that seemed to prefer quarterly rather than monthly reporting, though we can revisit that if we get more input on that specific point. For reference, the latest public version of for the Registries is available at https://tools.ietf.org/html/draft-lozano-icann-registry-interfaces
Thanks, and have a great weekend, all!
Amy
*From:* Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Sara Bockey *Sent:* Thursday, February 22, 2018 4:33 PM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Amy,
Additionally, it would be helpful if you could provide a bit more info re *Report Model, Issue 2*. Does ICANN’s reporting interface allow for files to be uploaded or is it a fill in the blank interface? If uploads are allowed, is there a limit on file size, type of file that can be used? Any additional information on how this interface works or is intended to work that would be very helpful.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Sara Bockey <sbockey@godaddy.com <mailto:sbockey@godaddy.com>> *Date: *Thursday, February 22, 2018 at 1:51 PM *To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Amy,
As you know, several registrars were not able to attend Tuesday’s call and I think it’s safe to say many members a facing bandwidth issues.
As you also know, GDPR is fast approaching and several sessions were held this week on the topic. GDPR is mission critical and requires a lot of registrar time investment. That said, it is likely that IRT members have not had a chance to listen to the recording or catch up on the mailing list. Therefore, I think it would be appropriate to allow an additional week to respond to our punch list below. There is no reason why we cannot allow this additional time. We are not facing a hard deadline as with GDPR, and it is very important for this IRT to produce quality work, not quick work.
Thanks,
Sara
*sara bockey*
*sr. policy manager | **Go**Daddy^™ *
*sbockey@godaddy.com <mailto:sbockey@godaddy.com> 480-366-3616*
*skype: sbockey*
//
/This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments./
*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Date: *Thursday, February 22, 2018 at 3:55 AM *To: *"gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> *Subject: *Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call
Dear Colleagues,
This is a reminder to please submit your input on the points below no later than your EOD Friday.
We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week.
Best,
Amy
Sent from my iPhone
On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/.
*Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb.*
*Monthly Reporting Specification*
1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point.
4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields.
*PP Applicant Guide*
1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP).
*LEA Disclosure Framework Specification*
1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that
1. If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then 2. The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. 3. *IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period.*
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@icann.org<mailto:amy.bivins@icann.org>
www.icann.org<http://www.icann.org>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
Regarding LEA and action within 24 hours, I still prefer this language: Where a disclosure request is categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Or at the very minimum, this: Where a disclosure request is categorized as High Priority, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. I know Steve thinks this is redundant due to Section 4.2.2, but I would argue that redundancy is necessary. Otherwise, there is an extreme likelihood of someone citing that section and saying “See! They are not complying with the agreement!” The wording as written is simply too restrictive and creates the perception of a requirement to disclose within 24 hrs. You can footnote and cite the related sections all you want, saying “must be actions in 24 hrs” is problematic. If your argument is that isn’t not restrictive due to Section 4.2.2 and the definition for “action” then there is not harm in being specific and clear in expection. I propose we use the proposed language above or some variation that is acceptable to Registrars. Thanks! sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
I’ve never been a fan of using “action” as a verb. So if the goal is clarification, then why don’t we say provider “will take one of the actions listed in 4.2” within 24 hours after receiving a high priority request. No one could rationally perceive this as requiring disclosure within 24 hours, since disclosure is only one of the actions listed in 4.2. (I would also be fine with changing the title of section 4.2 to “Disclosure or Refusal to Disclose,” which would be more accurate.) If , however, the goal is dilution of the requirement to a “best efforts” standard, then Sara’s language may do the trick (though without clarifying what “action” means as a verb), and I would oppose that. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Friday, February 23, 2018 9:54 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Regarding LEA and action within 24 hours, I still prefer this language: Where a disclosure request is categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Or at the very minimum, this: Where a disclosure request is categorized as High Priority, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. I know Steve thinks this is redundant due to Section 4.2.2, but I would argue that redundancy is necessary. Otherwise, there is an extreme likelihood of someone citing that section and saying “See! They are not complying with the agreement!” The wording as written is simply too restrictive and creates the perception of a requirement to disclose within 24 hrs. You can footnote and cite the related sections all you want, saying “must be actions in 24 hrs” is problematic. If your argument is that isn’t not restrictive due to Section 4.2.2 and the definition for “action” then there is not harm in being specific and clear in expection. I propose we use the proposed language above or some variation that is acceptable to Registrars. Thanks! sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/<https://participate.icann.org/p39onhjd1g1/>. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl>
I agree with Steve on saying that the provider “will take one of the actions listed in 4.2” within 24 hours after receiving a high priority request. I don’t particularly like the title he’s proposed for section 4.2 and I definitely oppose any effort to allow people to not reply within 24 hours with at least a “yes,” “no,” or “we need more information” to emergency requests from law enforcement. Even 24 hours is really way too long, which is why it’s an emergency request, but I can support this proposal in the hopes that, most of the time, providers will respond much more rapidly than that. Thank you all for listening and giving this important issue due consideration. Peter Roman Senior Counsel Computer Crime & Intellectual Property Section Criminal Division U.S. Department of Justice 1301 New York Ave.<x-apple-data-detectors://7>, NW Washington, DC 20530 (202) 305-1323 peter.roman@usdoj.gov<mailto:peter.roman@usdoj.gov> On Feb 23, 2018, at 4:33 PM, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: I’ve never been a fan of using “action” as a verb. So if the goal is clarification, then why don’t we say provider “will take one of the actions listed in 4.2” within 24 hours after receiving a high priority request. No one could rationally perceive this as requiring disclosure within 24 hours, since disclosure is only one of the actions listed in 4.2. (I would also be fine with changing the title of section 4.2 to “Disclosure or Refusal to Disclose,” which would be more accurate.) If , however, the goal is dilution of the requirement to a “best efforts” standard, then Sara’s language may do the trick (though without clarifying what “action” means as a verb), and I would oppose that. Steve Metalitz <image001.gif> Steven J. Metalitz | Partner, through his professional corporation T: 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 [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Friday, February 23, 2018 9:54 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Regarding LEA and action within 24 hours, I still prefer this language: Where a disclosure request is categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Or at the very minimum, this: Where a disclosure request is categorized as High Priority, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. I know Steve thinks this is redundant due to Section 4.2.2, but I would argue that redundancy is necessary. Otherwise, there is an extreme likelihood of someone citing that section and saying “See! They are not complying with the agreement!” The wording as written is simply too restrictive and creates the perception of a requirement to disclose within 24 hrs. You can footnote and cite the related sections all you want, saying “must be actions in 24 hrs” is problematic. If your argument is that isn’t not restrictive due to Section 4.2.2 and the definition for “action” then there is not harm in being specific and clear in expection. I propose we use the proposed language above or some variation that is acceptable to Registrars. Thanks! sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Thursday, February 22, 2018 at 3:55 AM To: "gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Summary, action items from today's PP IRT call Dear Colleagues, This is a reminder to please submit your input on the points below no later than your EOD Friday. We will make any final edits to the PPAA draft based on this feedback and intend to send you the updated draft on Monday as soon as the final edits are complete and reviewed internally. You aren’t expected to review the draft prior to Tuesday’s meeting-I realize this is a tight turnaround-I will explain edits that were made so that you can more easily review the updated draft after our call next week. Best, Amy Sent from my iPhone On Feb 20, 2018, at 12:27 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Dear Colleagues, Thank you for your active participation on today’s Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency—IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission—on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today’s meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format—on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields—on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today’s call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate “total” numbers for requests for specific contacts, eliminate “publication” fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded “reasons for denial” fields. PP Applicant Guide 1. Issue 1: Shift to “rolling” application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many “essay” questions in favor of “checkbox” questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today’s call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today’s call, it appears that * If “action” is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
participants (15)
-
Amy Bivins -
Chris Pelling -
DiBiase, Gregory -
Eric Rokobauer -
Jennifer Gore -
Lindsay Hamilton-Reid -
Lisa Villeneuve -
Margie Milam -
Metalitz, Steven -
Michele Neylon - Blacknight -
Nick Shorey -
Roman, Peter (CRM) -
Sara Bockey -
theo geurts -
Volker Greimann