I’d like to thank CPH for their Proposed Hybrid SSAD Model.  As I stated at the beginning of my first intervention in today’s call, there is a lot to appreciate – it’s nice to see the recommendations from the draft report so clearly expressed in this clean format, even though it strays into implementation details.  (It is well known that I prefer to consider implementation while developing policy, though others may be less comfortable with that approach.)  I can also imagine that an implementation of this model would accommodate both semi-automated decision-making and/or adoption of a centralized model at a later date if so desired.

 My specific feedback on the Proposed Model is as follows:

• Leveraging existing ICANN systems, Standardized inputs, Increased transparency and accountability, One-stop shop for all requests, Efficiencies in reviewing and responding, Logging & Auditing
• These sections all look great.
• Clearly defined roles and responsibilities
• I am less excited about this section, because I still think we should allocate the responsibilities in order to minimize the processing under the control of a CP, per the Belgian DPA letter cited.
• Ideally, CP’s processing would be limited to initial collection, explanation of intended processing, securing the data against breaches, and the like. 
• I do agree that this Proposal does indeed clarify those topics, though.
• Disclosure Request Process:
• Sections 1-3 look great.
• Section 4’s suggestion to use an existing portal seems good (I am not familiar with NSP). 
• I would note that even though the Proposal is focused on tickets being routed exclusively to individual contracted parties, the portal could easily redirect tickets to any party, even an entity providing a centralized function, should any contracted parties elect to outsource this function to a common decider.  In this sense, it provides some future-proofing.
• Section 5 should clearly define “automated confirmation” as something like “confirmation within seconds or minutes except during exceptional system failure”. 
• This is the sort of detail which is likely to be lost between recommendation and implementation, and could result in an expectation that a “two nines” availability level is acceptable, or that a system designed for 2-day latency is acceptable, or that automated confirmation is only required during business hours. 
• The automated notification to ICANN compliance should have a similar latency and availability spec.
• I really don’t know how to respond to 6d.  30 days is a very long time and will be wholly inadequate to stop consumer fraud and malware attacks.  I think you know this, and I don’t understand why you would include it in an otherwise reasonable proposal.

 /marksv

From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Crossman, Matthew via Gnso-epdp-team
Sent: Tuesday, January 7, 2020 1:41 PM
To: gnso-epdp-team@icann.org
Subject: [EXTERNAL] Re: [Gnso-epdp-team] For your review - latest version of draft Initial Report, deadline 7 January 2020

EPDP Team,

Happy New Year.  As part of the CPH comments on the revised draft report, please see the attached CPH proposal for a path forward to completing our work on a disclosure model.

We look forward to discussing further with this group.

Best,

Matt

From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Marika Konings
Sent: Friday, January 3, 2020 11:50 AM
To: gnso-epdp-team@icann.org
Subject: Re: [Gnso-epdp-team] For your review - latest version of draft Initial Report, deadline 7 January 2020

Happy New Year everyone – here is a quick reminder of the upcoming deadline of 7 January 2020 to provide your group’s input on the latest version of the draft Initial Report (see instructions below).

Best regards,

Caitlin, Berry and Marika

From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of Marika Konings <marika.konings@icann.org>
Date: Friday, December 20, 2019 at 21:01
To: "gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org>
Subject: [Gnso-epdp-team] For your review - latest version of draft Initial Report, deadline 7 January 2020

Ho, ho, ho, EPDP Team,

As promised, your early Christmas present has arrived! The latest version of the draft Initial Report has been posted for your review (see https://community.icann.org/x/BQZxBw). In this clean version, staff has incorporated the latest language of the building blocks that has been reviewed over the last couple of weeks and made a number of minor updates to address input already received. Remaining comments and text highlighted in yellow concern items that will need to be further reviewed and discussed by the EPDP Team in upcoming meetings.

For those interested, we have also posted a redline version (pdf document) so you can see all the edits made as well as comments resolved. If there are any comments or edits that have been applied / resolved but which in your group’s opinion should be further considered, please mark these as such in the new google doc.

As a reminder:

• Please do not reopen previously closed discussions unless there is new information to consider.
• If you have concerns about certain section, please provide alternative language to address your concern but also factor in other perspectives expressed to date.
• Please do not redline but provide language suggestions in the form of comments so that these can be reviewed by all before being applied.
• Minor edits (grammar, style) can be sent to the staff support team directly.

Your group’s input is due at the latest by 7 January 2020.

Happy reading and happy holidays!!

Caitlin, Berry and Marika