SSAD as a means of publishing non-personal data
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
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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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... -- 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. This email and any files transmitted are confidential and intended only for the person(s) directly addressed. If you are not the intended recipient, any use, copying, transmission, distribution, or other forms of dissemination is strictly prohibited. If you have received this email in error, please notify the sender immediately and permanently delete this email with any files that may be attached. On Thu, Apr 22, 2021 at 8:02 AM 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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participants (3)
-
Alan Greenberg -
Steve Crocker -
Volker Greimann