Hi Brian,

I think a lot of the details will still need to be fleshed out, but I see this proposal as mutually beneficial:- by introducing SSAD light for what essentially boils down to automatable requests, usage costs would be significantly driven down for requesters.
I must admit that much of this has not yet been discussed with the registrar community at large, but I see consensus here as possible, if not likely.

My proposal boils down to:
- automated SSAD disclosures for registration data that has been identified (in whatever way we ultimately all can agree upon) as either not containing personal information or as having received the registrants consent for publication
- lower access requirements for access to such data as risk of disclosure of personal information is low. (model: German trade register)
- lower fees for accessing an automated-response query (same model)
- lower risk of wrongful disclosure as requestors are known. Law enforcement may have privileged requester status that would prevent disclosure of their identity, but would still be auditable within SSAD.
- no need for CPs to build out a separate system, standard SSAD implementation with automated disclosure elements would be sufficient.

Open questions:
- Criteria for identification of data sets not containing PII (self-ID)
- Criteria by which third parties could see whether automated disclosure is possible (a: flag in RDAP; b: response to basic query in SSAD that this disclosure would be automated; c: ???)
- Best road to implementation? Is full PDP needed?

The days of the RDS as an all-you-can-leech source of personal information are over. This could be the best chance of a reasonable alternative.

I think constructive suggestions on how to improve the model while preserving its strengths could really bring us all forward.



-- 
Volker A. Greimann
General Counsel and Policy Manager
KEY-SYSTEMS GMBH

T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
W: www.key-systems.net

Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835
CEO: Oliver Fries and Robert Birkner

Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.

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On Thu, Apr 22, 2021 at 7:29 PM King, Brian via Gnso-epdp-team <gnso-epdp-team@icann.org> wrote:
Hi Volker,

Hoping to clarify your proposal so we can consider it fully, are you proposing to automate SSAD disclosure for domains whose registrants have self-designated that the registrant is a legal entity and the RDS data does not include personal data (fulfilling Milton’s principle of self-designation)? 

Brian J. King​
Head of Policy and Advocacy, Intellectual Property Group


T +1 443 761 3726​

clarivate.com​

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