Re: [Gdd-gnso-ppsai-impl] Action items from today's PP IRT call
Hi- In advance of tomorrow’s call, here are a few issues to consider related to the IP related text: * The Final Report states: Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy. I may have missed this, but it seems the Agreement should include an obligation on the Provider to conduct a human review of the requests. Also, is there language regarding the rebuttable presumption of noncompliance if there are high-volume automated electronic responses to a request? * How does the IP requester know where to send the requests or that the domain name is a privacy/proxy registration? Specification 3 doesn’t seem to include a unique label for P/P Providers nor does it include the Abuse Point of Contact information for the Provider. All the best, Margie 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: Tuesday, August 15, 2017 at 12:40 PM To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Action items from today's PP IRT call Hello, All, Thanks so much for your participation on today’s IRT call. I’ve updated the issues list (attached) with the input we received on this morning’s call. We have several outstanding discussion topics that we are requesting your feedback on via the list this week (requested deadline of 21 August): 1. Any additional feedback on PPAA issue 1: definitions (outlined in detail in attached slides from this week’s meeting) 1. Any additional feedback on PPAA issue 3: amendment/negotiation process. Edits were proposed by ICANN this week to allow proposed amendments to the PPAA to be considered by a working group convened by the GNSO or the Privacy/Proxy Stakeholder Group (if one is ever created). During today’s call, it was recommended by an IRT member that this should be limited, such that if there is ever a stakeholder group, its members can participate in the GNSO-convened group, but would not replace the GNSO-convened group in the PPAA amendment negotiation process. For reference, for the RAA negotiation process, the “working group” for negotiations is convened by the RrSG (See 2013 RAA Section 7.4.1). IRT feedback is requested on the proposed edits as well as the recommendation raised on today’s call. 1. Any additional feedback on PPAA issue 21: RAA synchronization. The IRT was asked whether any future updates to the RAA involving sections that are adapted in the PPAA should result in automatic updates to the PPAA. It was recommended on today’s call that updates could be synchronized with the PPAA, but this should not be automatic. Any proposed updates to the PPAA as a result of RAA updates should be presented to the working group (referenced in Item 2, above) for approval. IRT feedback is sought on the topic of synchronization in general, as well as the recommendation made on today’s call. In addition, feedback is sought on whether, if we do decide to have an approval mechanism before changes go into effect, the working group should always be the approval mechanism or whether other means, such as a public comment forum, could also be used. 1. Leading into next week’s continued discussion of the LEA framework, additional IRT feedback is requested on the proposed edit from the PSWG, that would reduce the time to review requests from LEA from 2 business days to 24 hours (See PPAA Issue 19 in attached issues list). IRT feedback on this topic has not produced a clear consensus on this topic. Please consider this issue and come prepared to discuss this topic on next week’s call, with the goal of reaching a resolution on this topic. 1. Customer Data Accuracy (See item 15 in issues list). It was noted on-list and on today’s call that the requirements in the draft Customer Data Accuracy Specification and Section 3.5.4.1, including pending updates based on IRT input, may result in some inconsistencies or lack of clarity surrounding requirements for providers. Please provide any further input on this topic. ICANN will revisit these provisions, taking into account IRT feedback, and propose language to clarify these requirements. Thanks so much in advance for your consideration of these items. For next week’s call, we are planning to discuss: * The PSWG-proposed update to the LEA framework, * Proposed next steps on data retention based on IRT feedback, * The IP framework, * ICANN reporting requirements, and * Any IRT feedback on the “business dealings” section of the PPAA (section 3.5)(this was a topic suggested by an IRT member). If you have questions or comments in the interim, please don’t hesitate to send them to the list. 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=DwMFAg&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=y0IJlehWkqe8Cvgwr0_xIC17p5jij_NIKHABIsGUpoc&s=xP_PrM51IEyZMR_PN82obI-6ZE8zn65xSPbaexvt0xY&e=>
Hi Margie, Thanks for providing these comments ahead of today’s call! On the first point, the IP framework is substantively identical to the framework included in the Policy recommendations, which did not include either of these points. I’d encourage you to raise these on the call today so that the group can discuss whether these should be added. On the second point (how will the IP holder know where to send requests), there are a few different ways the IP holder could obtain the provider’s contact information. The IP framework requires the provider to establish a point of contact for reporting purposes and, pursuant to Section 3.12 of the PPAA draft, providers are required to post the abuse contact information on their website. In addition, we are going to be discussing the RDDS labeling requirements again in a week or two. The current draft labeling specification would require that all registrations involving a Privacy/Proxy Service be labeled as such. The label would be required to include a URL/link to the ICANN-managed listing of accredited providers, which will include each provider’s contact information. I hope this helps, and thanks for starting this discussion! 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> From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Margie Milam Sent: Monday, August 21, 2017 6:39 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's PP IRT call Hi- In advance of tomorrow’s call, here are a few issues to consider related to the IP related text: * The Final Report states: Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy. I may have missed this, but it seems the Agreement should include an obligation on the Provider to conduct a human review of the requests. Also, is there language regarding the rebuttable presumption of noncompliance if there are high-volume automated electronic responses to a request? * How does the IP requester know where to send the requests or that the domain name is a privacy/proxy registration? Specification 3 doesn’t seem to include a unique label for P/P Providers nor does it include the Abuse Point of Contact information for the Provider. All the best, Margie 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: Tuesday, August 15, 2017 at 12:40 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: [Gdd-gnso-ppsai-impl] Action items from today's PP IRT call Hello, All, Thanks so much for your participation on today’s IRT call. I’ve updated the issues list (attached) with the input we received on this morning’s call. We have several outstanding discussion topics that we are requesting your feedback on via the list this week (requested deadline of 21 August): 1. Any additional feedback on PPAA issue 1: definitions (outlined in detail in attached slides from this week’s meeting) 1. Any additional feedback on PPAA issue 3: amendment/negotiation process. Edits were proposed by ICANN this week to allow proposed amendments to the PPAA to be considered by a working group convened by the GNSO or the Privacy/Proxy Stakeholder Group (if one is ever created). During today’s call, it was recommended by an IRT member that this should be limited, such that if there is ever a stakeholder group, its members can participate in the GNSO-convened group, but would not replace the GNSO-convened group in the PPAA amendment negotiation process. For reference, for the RAA negotiation process, the “working group” for negotiations is convened by the RrSG (See 2013 RAA Section 7.4.1). IRT feedback is requested on the proposed edits as well as the recommendation raised on today’s call. 1. Any additional feedback on PPAA issue 21: RAA synchronization. The IRT was asked whether any future updates to the RAA involving sections that are adapted in the PPAA should result in automatic updates to the PPAA. It was recommended on today’s call that updates could be synchronized with the PPAA, but this should not be automatic. Any proposed updates to the PPAA as a result of RAA updates should be presented to the working group (referenced in Item 2, above) for approval. IRT feedback is sought on the topic of synchronization in general, as well as the recommendation made on today’s call. In addition, feedback is sought on whether, if we do decide to have an approval mechanism before changes go into effect, the working group should always be the approval mechanism or whether other means, such as a public comment forum, could also be used. 1. Leading into next week’s continued discussion of the LEA framework, additional IRT feedback is requested on the proposed edit from the PSWG, that would reduce the time to review requests from LEA from 2 business days to 24 hours (See PPAA Issue 19 in attached issues list). IRT feedback on this topic has not produced a clear consensus on this topic. Please consider this issue and come prepared to discuss this topic on next week’s call, with the goal of reaching a resolution on this topic. 1. Customer Data Accuracy (See item 15 in issues list). It was noted on-list and on today’s call that the requirements in the draft Customer Data Accuracy Specification and Section 3.5.4.1, including pending updates based on IRT input, may result in some inconsistencies or lack of clarity surrounding requirements for providers. Please provide any further input on this topic. ICANN will revisit these provisions, taking into account IRT feedback, and propose language to clarify these requirements. Thanks so much in advance for your consideration of these items. For next week’s call, we are planning to discuss: * The PSWG-proposed update to the LEA framework, * Proposed next steps on data retention based on IRT feedback, * The IP framework, * ICANN reporting requirements, and * Any IRT feedback on the “business dealings” section of the PPAA (section 3.5)(this was a topic suggested by an IRT member). If you have questions or comments in the interim, please don’t hesitate to send them to the list. 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=DwMFAg&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=y0IJlehWkqe8Cvgwr0_xIC17p5jij_NIKHABIsGUpoc&s=xP_PrM51IEyZMR_PN82obI-6ZE8zn65xSPbaexvt0xY&e=>
participants (2)
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Amy Bivins -
Margie Milam