Question 5 to the Community - clarification needed
In preparing for tomorrow's presentation, I realized that Question 5 to the Community omits an important word, "anonymized." We should correct this. Here is the Question from the Initial Report: EPDP Team Question for Community Input #5 Does this guidance as written provide sufficient information and resources to Registrars and Registry Operators who wish to publish a registrant- or registration-based email address? If not, what is missing and why? Taken literally, this might leave the impression that the Recommendation is to publish a standard email address. In fact, our deliberations involved the publication of an anonymized (or more precisely, pseudonymized) email address. I request that we correct this oversight both so that our intention is clear and so that the public comments solicited focus on the real topic to consider - whether to publish some form of an anonymized email address. I propose that we publish a corrected version of the Initial Report that inserts the word "anonymized" prior to "registrant- or registration-based email address" to correct this oversight. Kind regards, Laureen Kapin Acting Assistant Director Division of Consumer Response and Operations Bureau of Consumer Protection Federal Trade Commission
do you mean pseudonymized rather than anonymized? On Tue, Jun 15, 2021 at 3:36 PM Kapin, Laureen via Gnso-epdp-team < gnso-epdp-team@icann.org> wrote:
In preparing for tomorrow’s presentation, I realized that Question 5 to the Community omits an important word, “anonymized.” We should correct this.
Here is the Question from the Initial Report:
*EPDP Team Question for Community Input #5*
*Does this guidance as written provide sufficient information and resources to Registrars and Registry Operators who wish to publish a registrant- or registration-based email address? If not, what is missing and why? *
Taken literally, this might leave the impression that the Recommendation is to publish a standard email address. In fact, our deliberations involved the publication of an anonymized (or more precisely, pseudonymized) email address. I request that we correct this oversight both so that our intention is clear and so that the public comments solicited focus on the real topic to consider – whether to publish some form of an anonymized email address.
I propose that we publish a corrected version of the Initial Report that inserts the word “anonymized” prior to “registrant- or registration-based email address” to correct this oversight.
Kind regards,
Laureen Kapin
*Acting Assistant Director*
*Division of Consumer Response and Operations*
*Bureau of Consumer Protection*
*Federal Trade Commission*
_______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Please also note that the preceding section in the Initial Report defines these terms (note, there are also some footnotes that go with these definitions): * "Registrant-based email contact", means “an email for all domains registered by a unique registrant [sponsored by a given Registrar] OR [across Registrars], which is intended to be pseudonymous data when processed by non-contracted parties. * "Registration-based email contact", means “a separate single use email for each domain name registered by a unique registrant, which is intended to be anonymous data when processed by non-contracted parties. We can make sure that a reference to these definitions is included in the public comment form to make sure that those that only look at the form have the appropriate context. Best regards, Caitlin, Berry and Marika From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of Becky Burr via Gnso-epdp-team <gnso-epdp-team@icann.org> Reply to: Becky Burr <becky.burr@board.icann.org> Date: Tuesday, 15 June 2021 at 21:59 To: "Kapin, Laureen" <LKAPIN@ftc.gov> Cc: "gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] Question 5 to the Community - clarification needed do you mean pseudonymized rather than anonymized? On Tue, Jun 15, 2021 at 3:36 PM Kapin, Laureen via Gnso-epdp-team <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>> wrote: In preparing for tomorrow’s presentation, I realized that Question 5 to the Community omits an important word, “anonymized.” We should correct this. Here is the Question from the Initial Report: EPDP Team Question for Community Input #5 Does this guidance as written provide sufficient information and resources to Registrars and Registry Operators who wish to publish a registrant- or registration-based email address? If not, what is missing and why? Taken literally, this might leave the impression that the Recommendation is to publish a standard email address. In fact, our deliberations involved the publication of an anonymized (or more precisely, pseudonymized) email address. I request that we correct this oversight both so that our intention is clear and so that the public comments solicited focus on the real topic to consider – whether to publish some form of an anonymized email address. I propose that we publish a corrected version of the Initial Report that inserts the word “anonymized” prior to “registrant- or registration-based email address” to correct this oversight. Kind regards, Laureen Kapin Acting Assistant Director Division of Consumer Response and Operations Bureau of Consumer Protection Federal Trade Commission _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org<mailto:Gnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Although what you describe about the rest of the report is accurate, I still think the omission of the word “anonymized” is simply a mistake that we should correct and to let it stand uncorrected will cause confusion. Might you explain why there is resistance to correcting this simple error? I suspect that PDP’s have published corrected versions before. Kind regards, Laureen Kapin Acting Assistant Director Division of Consumer Response and Operations Bureau of Consumer Protection Federal Trade Commission From: Marika Konings <marika.konings@icann.org> Sent: Tuesday, June 15, 2021 4:36 PM To: Becky Burr <becky.burr@board.icann.org>; Kapin, Laureen <LKAPIN@ftc.gov> Cc: gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Question 5 to the Community - clarification needed Please also note that the preceding section in the Initial Report defines these terms (note, there are also some footnotes that go with these definitions): · "Registrant-based email contact", means “an email for all domains registered by a unique registrant [sponsored by a given Registrar] OR [across Registrars], which is intended to be pseudonymous data when processed by non-contracted parties. · "Registration-based email contact", means “a separate single use email for each domain name registered by a unique registrant, which is intended to be anonymous data when processed by non-contracted parties. We can make sure that a reference to these definitions is included in the public comment form to make sure that those that only look at the form have the appropriate context. Best regards, Caitlin, Berry and Marika From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of Becky Burr via Gnso-epdp-team <gnso-epdp-team@icann.org> Reply to: Becky Burr <becky.burr@board.icann.org> Date: Tuesday, 15 June 2021 at 21:59 To: "Kapin, Laureen" <LKAPIN@ftc.gov> Cc: "gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] Question 5 to the Community - clarification needed do you mean pseudonymized rather than anonymized? On Tue, Jun 15, 2021 at 3:36 PM Kapin, Laureen via Gnso-epdp-team <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>> wrote: In preparing for tomorrow’s presentation, I realized that Question 5 to the Community omits an important word, “anonymized.” We should correct this. Here is the Question from the Initial Report: EPDP Team Question for Community Input #5 Does this guidance as written provide sufficient information and resources to Registrars and Registry Operators who wish to publish a registrant- or registration-based email address? If not, what is missing and why? Taken literally, this might leave the impression that the Recommendation is to publish a standard email address. In fact, our deliberations involved the publication of an anonymized (or more precisely, pseudonymized) email address. I request that we correct this oversight both so that our intention is clear and so that the public comments solicited focus on the real topic to consider – whether to publish some form of an anonymized email address. I propose that we publish a corrected version of the Initial Report that inserts the word “anonymized” prior to “registrant- or registration-based email address” to correct this oversight. Kind regards, Laureen Kapin Acting Assistant Director Division of Consumer Response and Operations Bureau of Consumer Protection Federal Trade Commission _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org<mailto:Gnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
I think the context of the question makes it clear, but as the context is lost during the presentation if not explicitly raised, there may be confusion of the listeners. For the purposes of the presentation, we should clarify, for the purposes of the report itself, it is fine as is. -- 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. <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> Virus-free. www.avast.com <https://www.avast.com/sig-email?utm_medium=email&utm_source=link&utm_campaign=sig-email&utm_content=webmail> <#DAB4FAD8-2DD7-40BB-A1B8-4E2AA1F9FDF2> On Tue, Jun 15, 2021 at 10:44 PM Kapin, Laureen via Gnso-epdp-team < gnso-epdp-team@icann.org> wrote:
Although what you describe about the rest of the report is accurate, I still think the omission of the word “anonymized” is simply a mistake that we should correct and to let it stand uncorrected will cause confusion. Might you explain why there is resistance to correcting this simple error? I suspect that PDP’s have published corrected versions before.
Kind regards,
Laureen Kapin
*Acting Assistant Director*
*Division of Consumer Response and Operations*
*Bureau of Consumer Protection*
*Federal Trade Commission*
*From:* Marika Konings <marika.konings@icann.org> *Sent:* Tuesday, June 15, 2021 4:36 PM *To:* Becky Burr <becky.burr@board.icann.org>; Kapin, Laureen < LKAPIN@ftc.gov> *Cc:* gnso-epdp-team@icann.org *Subject:* Re: [Gnso-epdp-team] Question 5 to the Community - clarification needed
Please also note that the preceding section in the Initial Report defines these terms (note, there are also some footnotes that go with these definitions):
· "Registrant-based email contact", means “an email for all domains registered by a unique registrant [sponsored by a given Registrar] OR [across Registrars], which is intended to be pseudonymous data when processed by non-contracted parties.
· "Registration-based email contact", means “a separate single use email for each domain name registered by a unique registrant, which is intended to be anonymous data when processed by non-contracted parties.
We can make sure that a reference to these definitions is included in the public comment form to make sure that those that only look at the form have the appropriate context.
Best regards,
Caitlin, Berry and Marika
*From: *Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of Becky Burr via Gnso-epdp-team <gnso-epdp-team@icann.org> *Reply to: *Becky Burr <becky.burr@board.icann.org> *Date: *Tuesday, 15 June 2021 at 21:59 *To: *"Kapin, Laureen" <LKAPIN@ftc.gov> *Cc: *"gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org> *Subject: *Re: [Gnso-epdp-team] Question 5 to the Community - clarification needed
do you mean pseudonymized rather than anonymized?
On Tue, Jun 15, 2021 at 3:36 PM Kapin, Laureen via Gnso-epdp-team < gnso-epdp-team@icann.org> wrote:
In preparing for tomorrow’s presentation, I realized that Question 5 to the Community omits an important word, “anonymized.” We should correct this.
Here is the Question from the Initial Report:
*EPDP Team Question for Community Input #5*
*Does this guidance as written provide sufficient information and resources to Registrars and Registry Operators who wish to publish a registrant- or registration-based email address? If not, what is missing and why? *
Taken literally, this might leave the impression that the Recommendation is to publish a standard email address. In fact, our deliberations involved the publication of an anonymized (or more precisely, pseudonymized) email address. I request that we correct this oversight both so that our intention is clear and so that the public comments solicited focus on the real topic to consider – whether to publish some form of an anonymized email address.
I propose that we publish a corrected version of the Initial Report that inserts the word “anonymized” prior to “registrant- or registration-based email address” to correct this oversight.
Kind regards,
Laureen Kapin
*Acting Assistant Director*
*Division of Consumer Response and Operations*
*Bureau of Consumer Protection*
*Federal Trade Commission*
_______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
_______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
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participants (4)
-
Becky Burr -
Kapin, Laureen -
Marika Konings -
Volker Greimann