Re: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal
Amy / Nick I’ll try to make the call today, but I am having issues juggling meetings / calls etc., In relation to the document shared by Nick: 1.5 – is there a list of priority levels? One of my concerns with this is that the lazy method would be to always set the level as “fastest” or “top priority”. I see there are two rather vague ones mentioned elsewhere in the document. 3.2 the 24 hour timeframe is not workable. I assume the timing has been copied from 3.18 in the 2013 RAA. Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very “legalistic” so it would require the provider to get legal advice before being able to respond. I don’t think I’d be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable. I’d be happy to acknowledge the request within 24 hours, but I don’t think that the current wording is workable. The language around “secure mechanism” does concern me – it needs to be fleshed out a bit 4.2.3 – “This must be completed prior to any Customer Notification irrespective of the reason for refusal” – I don’t see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it’s inconsistent with the grounds for refusal. 4.3.3 – sorry, but again I don’t see why we’d agree to this. 6.3 – this seems to contradict the other references to customer notification Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: <gdd-gnso-ppsai-impl-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: Sunday 4 June 2017 at 12:10 To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists@nickshorey.com<mailto:lists@nickshorey.com>> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Cc: Fabien Betremieux <fabien.betremieux@icann.org<mailto:fabien.betremieux@icann.org>> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists@nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nick...> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=DwM...> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone
Hi all I will not be able to attend the meeting today. Apologies. Many thanks Lindsay From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Michele Neylon - Blacknight Sent: 06 June 2017 13:56 To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Amy / Nick I’ll try to make the call today, but I am having issues juggling meetings / calls etc., In relation to the document shared by Nick: 1.5 – is there a list of priority levels? One of my concerns with this is that the lazy method would be to always set the level as “fastest” or “top priority”. I see there are two rather vague ones mentioned elsewhere in the document. 3.2 the 24 hour timeframe is not workable. I assume the timing has been copied from 3.18 in the 2013 RAA. Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very “legalistic” so it would require the provider to get legal advice before being able to respond. I don’t think I’d be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable. I’d be happy to acknowledge the request within 24 hours, but I don’t think that the current wording is workable. The language around “secure mechanism” does concern me – it needs to be fleshed out a bit 4.2.3 – “This must be completed prior to any Customer Notification irrespective of the reason for refusal” – I don’t see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it’s inconsistent with the grounds for refusal. 4.3.3 – sorry, but again I don’t see why we’d agree to this. 6.3 – this seems to contradict the other references to customer notification Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: <gdd-gnso-ppsai-impl-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: Sunday 4 June 2017 at 12:10 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: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists@nickshorey.com<mailto:lists@nickshorey.com>> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Cc: Fabien Betremieux <fabien.betremieux@icann.org<mailto:fabien.betremieux@icann.org>> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists@nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nick...> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=DwM...> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone
Hi there Lindsay, Your apology has been noted for today's IRT meeting. Thank you so much, Michelle From: <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Lindsay Hamilton-Reid <Lindsay.Hamilton-Reid@fasthosts.com<mailto:Lindsay.Hamilton-Reid@fasthosts.com>> 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: Tuesday, June 6, 2017 at 8:50 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] Fwd: PSWG proposal Hi all I will not be able to attend the meeting today. Apologies. Many thanks Lindsay From: gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Michele Neylon - Blacknight Sent: 06 June 2017 13:56 To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Amy / Nick I'll try to make the call today, but I am having issues juggling meetings / calls etc., In relation to the document shared by Nick: 1.5 - is there a list of priority levels? One of my concerns with this is that the lazy method would be to always set the level as "fastest" or "top priority". I see there are two rather vague ones mentioned elsewhere in the document. 3.2 the 24 hour timeframe is not workable. I assume the timing has been copied from 3.18 in the 2013 RAA. Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very "legalistic" so it would require the provider to get legal advice before being able to respond. I don't think I'd be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable. I'd be happy to acknowledge the request within 24 hours, but I don't think that the current wording is workable. The language around "secure mechanism" does concern me - it needs to be fleshed out a bit 4.2.3 - "This must be completed prior to any Customer Notification irrespective of the reason for refusal" - I don't see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it's inconsistent with the grounds for refusal. 4.3.3 - sorry, but again I don't see why we'd agree to this. 6.3 - this seems to contradict the other references to customer notification Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: <gdd-gnso-ppsai-impl-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: Sunday 4 June 2017 at 12:10 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: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists@nickshorey.com<mailto:lists@nickshorey.com>> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Cc: Fabien Betremieux <fabien.betremieux@icann.org<mailto:fabien.betremieux@icann.org>> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists@nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nick...> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=DwM...> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone
Adding a couple questions/concerns about the PSWG proposal: 3.2.2: How does the Provider verify the identity of the Requestor? Would governments maintain a page with all of the law enforcement contacts that could submit a valid request, and we’d have to go check against that each time we received a request? 1.4 and 4.2: “Requested Information” includes things like credit card details that are outside the scope of this policy. Section 4.2.1 says the provider will disclose the Requested Information it holds against the account. As written, it seems like Requestors could use this framework to make requests totally unrelated to the contact details underlying privacy/protection. Shouldn’t the disclosure process in 4.2 only pertain to registrant contact details? Thanks, Greg From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Michele Neylon - Blacknight Sent: Tuesday, June 06, 2017 5:56 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Amy / Nick I’ll try to make the call today, but I am having issues juggling meetings / calls etc., In relation to the document shared by Nick: 1.5 – is there a list of priority levels? One of my concerns with this is that the lazy method would be to always set the level as “fastest” or “top priority”. I see there are two rather vague ones mentioned elsewhere in the document. 3.2 the 24 hour timeframe is not workable. I assume the timing has been copied from 3.18 in the 2013 RAA. Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very “legalistic” so it would require the provider to get legal advice before being able to respond. I don’t think I’d be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable. I’d be happy to acknowledge the request within 24 hours, but I don’t think that the current wording is workable. The language around “secure mechanism” does concern me – it needs to be fleshed out a bit 4.2.3 – “This must be completed prior to any Customer Notification irrespective of the reason for refusal” – I don’t see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it’s inconsistent with the grounds for refusal. 4.3.3 – sorry, but again I don’t see why we’d agree to this. 6.3 – this seems to contradict the other references to customer notification Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: <gdd-gnso-ppsai-impl-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: Sunday 4 June 2017 at 12:10 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: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists@nickshorey.com<mailto:lists@nickshorey.com>> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Cc: Fabien Betremieux <fabien.betremieux@icann.org<mailto:fabien.betremieux@icann.org>> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists@nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nick...> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=DwM...> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone
I want to concur with Michele’s comments below and similar comments he and others made during today’s meeting. In addition: ¶4.3.1 - I’m not certain that the Requestor (LEA) always has authority to set this timeframe. ¶6.1 – this language is simply not necessary. What a provider may or may not do goes far beyond the single consideration of “where such action does not conflict with national or international law(s).” It may be based on legal advice from the Provider’s counsel relating to a variety of issues. Thanks, Darcy From: <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Michele Neylon - Blacknight <michele@blacknight.com> Reply-To: <gdd-gnso-ppsai-impl@icann.org> Date: Tuesday, June 6, 2017 at 5:55 AM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Amy / Nick I’ll try to make the call today, but I am having issues juggling meetings / calls etc., In relation to the document shared by Nick: 1.5 – is there a list of priority levels? One of my concerns with this is that the lazy method would be to always set the level as “fastest” or “top priority”. I see there are two rather vague ones mentioned elsewhere in the document. 3.2 the 24 hour timeframe is not workable. I assume the timing has been copied from 3.18 in the 2013 RAA. Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very “legalistic” so it would require the provider to get legal advice before being able to respond. I don’t think I’d be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable. I’d be happy to acknowledge the request within 24 hours, but I don’t think that the current wording is workable. The language around “secure mechanism” does concern me – it needs to be fleshed out a bit 4.2.3 – “This must be completed prior to any Customer Notification irrespective of the reason for refusal” – I don’t see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it’s inconsistent with the grounds for refusal. 4.3.3 – sorry, but again I don’t see why we’d agree to this. 6.3 – this seems to contradict the other references to customer notification Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: <gdd-gnso-ppsai-impl-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: Sunday 4 June 2017 at 12:10 To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists@nickshorey.com> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins@icann.org> Cc: Fabien Betremieux <fabien.betremieux@icann.org> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. 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[linkedin.com] Web: www.nickshorey.com[nickshorey.com] On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins@icann.org> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
participants (5)
-
Darcy Southwell -
DiBiase, Gregory -
Lindsay Hamilton-Reid -
Michele Neylon - Blacknight -
Michelle DeSmyter