All:
I’ve been reviewing the draft report. On p
10 we are supposed to be setting out the basic principles
underlying the SSAD model.
In fact, we never quite do that. We need to
state right there that we have adopted a hybrid model, which
involves a centralized point for accreditation and for the
receipt of queries, but that disclosure decisions that are
made by the contracted party who is holding the data. We need
to state that simply and clearly. I propose the following
language for the first bullet:
• Requests for redacted data are made to a
centralized gateway administered by ICANN, which also
accredits entities to make queries. Disclosure decisions are
made by the contracted parties maintaining the data.
None of the other principles make any sense
until this is stated. E.g., the first bullet point talks about
automation but automation of what? Queries, authorization,
disclosure? The second bullet point talks about "further
streamlining and standardizing of disclosure requests" but
this makes no sense unless we have made it clear that the
model involves a centralized point for disclosure requests and
decentralized disclosure decisions.
Further down on p 11, in describing the
benefits, we do say that there is a single point for making
requests, but the P. 10 summary is what most people will read
first as the basic elements of the model, so we need to make
it clear there.
I think this addition is pretty
noncontroversial and hope we can go ahead with it.
Dr. Milton L Mueller
Georgia Institute of Technology
School of Public Policy
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