Alan,

Thanks for your note.  I can't tell if you are responding or had seen the note I sent several hours ago.  In that note, I said differentiated access is essential and we must include it in our thinking.  I pointed out that trying to design access to public data under the assumption, either implicit or explicit, that differentiated access will not exist leads to a design that is poor in multiple ways.

One key point I did not cover in the memo is the distinction between differentiated access as a concept and SSAD as a particular proposal for achieving some aspects of differentiated access.  As we have heard, there are criticisms of the proposed design and significant open issues that have not yet been addressed.  Among the open issues, the most important is fleshing out the matrix of purposes, groups intended to have access for each purpose, the data elements they should receive, and performance requirements.  The overwhelming proportion of requests will have to be satisfied quickly and automatically.  Manual review is tolerable for only a small fraction of the total set of requests.  The best way forward, in my view, is to tackle the open issues.  That's apparently outside the scope  phase EPDP 2A, but I think it is very much within scope to be clear that this is a requirement.

Thanks,

Steve


On Wed, Apr 21, 2021 at 11:02 PM Alan Greenberg via Gnso-epdp-team <gnso-epdp-team@icann.org> wrote:
There continues to be discussion regarding using the SSAD as a means
of "publishing" non-personal data.

I believe that this discussion is a distraction that takes focus from
what we should be working on. I say this for the following reason.

1. The SSAD does not exist, it may never exist, and if the Board does
approve it, it will likely take several years to implement (remember
we are 2 years into the implementation of Phase 1, and there is no
centralized hardware/software to design and implement for that).

2. Although we specified that anyone may be accredited, it is not at
all clear the amount of time it will take, nor what fee might be
charged. And unless the system allows accreditation without
authenticating the identity, this precludes anonymous queries.

3. We specified that the SSAD must be self-funding and that the users
must pay for its operating costs. Are those in favour of using the
SSAD for public data publishing proposing fees for such requests, or
no fees, and if the latter, who will pay for this usage?

4. There are multiple details of Phase 2 Recommendation 8 for
Contracted Party Authorization that simply make no sense in this
case, yet are part of the approved policy. And changing that policy
requires a PDP.

5. There does not seem to be any benefit of routing public-data
requests through the SSAD with its myriad rules, regulations and
processes when a vanilla RDAP server will suffice.

Alan

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