1. SSAD was approved by the PDPD consensus, by the GNSO council with sufficient votes and by the board. It will exist. If it does not, we will be forced back to the drawing board for another couple of years and the status quo will persist. If you prefer that over SSAD, go ahead and kill SSAD.
2. This would be questions for the implementation phase, but maybe some guidance would be helpful to put people here at ease. I do not think there needs to be authentication for basic SSAD access. The terms currently in place for domain name registration are fully sufficient for that access level: Validation of format of the data, verification of email address, valid payment method. This would be my personal view.
3. As this access level would require significantly lower barriers than full access, fees for this type of requests could be lower as well. For comparison, requests for data from the German trade register cost medium one-digit EUR amounts per request. The added benefit is that this common type of request could carry a base cost load for the system, allowing lower overall costs for all requests. Only leaving SSAD for personal data would on the other hand drive up costs. The more we include in SSAD, the better the price structure should be.
4. If we do need another PDP (not convinced that we do) this could be pre-determined and targeted. If we all agree now that we want this to happen, debate the specifics before the PDP is launched, the time needed for the actual PDP could be minimal.
5. To the contrary, there are a myrad of advantages: Use of existing infrastructure, lower overall SSAD fees, better protection of registrants, access controls, prevention of harvesting for illicit purposes (SPAM, phishing, etc) , requestor ID, reduced risk for CPs, no need to build out yet another system for a sub-category of domain names, no data transfer liability issues, etc. The list goes on and on...
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Volker A. Greimann
General Counsel and Policy Manager
KEY-SYSTEMS GMBH
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