Dear EPDP Team: Please find attached the draft Initial Report. As you review the draft, please be aware that the text highlighted in orange is still under review but has been included to give the Team a holistic idea of the Report’s status. Specifically, the orange text represents: Text not yet reviewed by the EPDP Team; Staff-proposed text to address comments provided on calls; or Placeholder text where further work is underway. As Janis noted during the Team’s last meeting, please review the draft and come prepared to Wednesday’s meeting ready to discuss the status of the draft Initial Report, with a specific focus on the readiness to publish for public comment. We have also attached the timeline slides Berry presented during ICANN66 to remind the Team of how the date we publish the Initial Report for public comment will affect the overall project timeline. To those celebrating: Happy Thanksgiving from the EPDP Leadership and Support Team! Best regards, Marika, Berry, and Caitlin
We (NCSG) will have a number of comments about the draft initial report which we hope will lead to some important modifications. One issue jumps out at me, however, and calls for an immediate response. The report outlines three models, 1. “Centralized” 2. “Decentralized” 3. “Hybrid.” My feeling is that no one on the EPDP team supports the so-called “decentralized” model, which is really a “No SSAD” model. As far as I can tell, the group has been debating between two options, an SSAD in which ICANN alone makes the ultimate disclosure decision, and an SSAD in which the contracted party makes the ultimate disclosure decision based on policies and procedures defined and enforced by ICANN. Happy to be corrected here, but I am not aware of any SG or AC represented on the EPDP team has favored no SSAD at all. I think it might distort public comment and dramatically exaggerate the divergence of views on EPDP for us to present #2 as a “model” that we are considering. That being said, I have heard some CPs say that they are worried that the cost benefit ratio of an SSAD might be so unfavorable as not to justify having one. (NCSG shares these concerns, but thinks the jury is still out.) If that is the basis for the so-called “decentralized” (no SSAD) approach, then the report should not propose that as one of three “models,” it should instead propose it as a reversion to the post temp spec status quo due to the lack of a favorable cost benefit ratio. I think the framing here matters a lot, in that we all seem to agree that standardizing and centralizing the request process would do all parties a lot of good. Why would we want the draft report to drastically understate the extent to which we have agreed on certain things? Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Caitlin Tubergen Sent: Thursday, November 28, 2019 1:01 PM To: gnso-epdp-team@icann.org Subject: [Gnso-epdp-team] Draft Initial Report Dear EPDP Team: Please find attached the draft Initial Report. As you review the draft, please be aware that the text highlighted in orange is still under review but has been included to give the Team a holistic idea of the Report’s status. Specifically, the orange text represents: 1. Text not yet reviewed by the EPDP Team; 2. Staff-proposed text to address comments provided on calls; or 3. Placeholder text where further work is underway. As Janis noted during the Team’s last meeting, please review the draft and come prepared to Wednesday’s meeting ready to discuss the status of the draft Initial Report, with a specific focus on the readiness to publish for public comment. We have also attached the timeline slides Berry presented during ICANN66 to remind the Team of how the date we publish the Initial Report for public comment will affect the overall project timeline. To those celebrating: Happy Thanksgiving from the EPDP Leadership and Support Team! Best regards, Marika, Berry, and Caitlin
Hi all, IPC is also compiling our comments on the draft report, and we will send those to the broader group soon. As you all know, I love to agree with Milton every chance I get, and happily this is one of those times. IPC also does not support representing “decentralized” as an SSAD model under consideration, for many of the reasons Milton notes below. If I can go so far, I suggest that the initial report indicate that we are working primarily toward the “centralized” model pending crucial input from the DPB. Brian J. King Director of Internet Policy and Industry Affairs T +1 443 761 3726 markmonitor.com<http://www.markmonitor.com> MarkMonitor Protecting companies and consumers in a digital world From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Mueller, Milton L Sent: Monday, December 2, 2019 11:44 AM To: Caitlin Tubergen <caitlin.tubergen@icann.org>; gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report We (NCSG) will have a number of comments about the draft initial report which we hope will lead to some important modifications. One issue jumps out at me, however, and calls for an immediate response. The report outlines three models, 1. “Centralized” 2. “Decentralized” 3. “Hybrid.” My feeling is that no one on the EPDP team supports the so-called “decentralized” model, which is really a “No SSAD” model. As far as I can tell, the group has been debating between two options, an SSAD in which ICANN alone makes the ultimate disclosure decision, and an SSAD in which the contracted party makes the ultimate disclosure decision based on policies and procedures defined and enforced by ICANN. Happy to be corrected here, but I am not aware of any SG or AC represented on the EPDP team has favored no SSAD at all. I think it might distort public comment and dramatically exaggerate the divergence of views on EPDP for us to present #2 as a “model” that we are considering. That being said, I have heard some CPs say that they are worried that the cost benefit ratio of an SSAD might be so unfavorable as not to justify having one. (NCSG shares these concerns, but thinks the jury is still out.) If that is the basis for the so-called “decentralized” (no SSAD) approach, then the report should not propose that as one of three “models,” it should instead propose it as a reversion to the post temp spec status quo due to the lack of a favorable cost benefit ratio. I think the framing here matters a lot, in that we all seem to agree that standardizing and centralizing the request process would do all parties a lot of good. Why would we want the draft report to drastically understate the extent to which we have agreed on certain things? Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Caitlin Tubergen Sent: Thursday, November 28, 2019 1:01 PM To: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: [Gnso-epdp-team] Draft Initial Report Dear EPDP Team: Please find attached the draft Initial Report. As you review the draft, please be aware that the text highlighted in orange is still under review but has been included to give the Team a holistic idea of the Report’s status. Specifically, the orange text represents: 1. Text not yet reviewed by the EPDP Team; 2. Staff-proposed text to address comments provided on calls; or 3. Placeholder text where further work is underway. As Janis noted during the Team’s last meeting, please review the draft and come prepared to Wednesday’s meeting ready to discuss the status of the draft Initial Report, with a specific focus on the readiness to publish for public comment. We have also attached the timeline slides Berry presented during ICANN66 to remind the Team of how the date we publish the Initial Report for public comment will affect the overall project timeline. To those celebrating: Happy Thanksgiving from the EPDP Leadership and Support Team! Best regards, Marika, Berry, and Caitlin
Ha, you spoiled the agreement, Brian. ;-)
If I can go so far, I suggest that the initial report indicate that we are working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus.
Ultimately, the "no-SSAD" "option" describes the status quo. In other words, if we as a group fail to reach consensus this is what we'll have, regardless of what we want. Maybe this can serve as encouragement to move away from extreme positions that have a rabbits chance in a snake pit to survive a consensus call... Volker Am 03.12.2019 um 13:26 schrieb Mueller, Milton L:
Ha, you spoiled the agreement, Brian. ;-)
If I can go so far, I suggest that the initial report indicate that we are
working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus.
_______________________________________________ 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.
-- 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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
That’s the correct way to put it, Volker. No consensus, no SSAD. Perhaps the draft report can be modified to indicate that. --MM From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Volker Greimann Sent: Tuesday, December 3, 2019 7:38 AM To: gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report Ultimately, the "no-SSAD" "option" describes the status quo. In other words, if we as a group fail to reach consensus this is what we'll have, regardless of what we want. Maybe this can serve as encouragement to move away from extreme positions that have a rabbits chance in a snake pit to survive a consensus call... Volker Am 03.12.2019 um 13:26 schrieb Mueller, Milton L: Ha, you spoiled the agreement, Brian. ;-)
If I can go so far, I suggest that the initial report indicate that we are working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus. _______________________________________________ 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. -- 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<http://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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
Dear All, Let me explain thinking behind the "Decentralized" model. It has been mentioned during the Team conversation that "status quo improved" can not be ruled out. Today there isn't system but decentralized mechanism of sending request for private registration information disclosure. Sometimes these requests are answered, sometimes remain without reply. Improvements in the current mechanism could be done through standardization of procedures that would be applied by both - requesting entities and responding entities without changing the decentralized nature of mechanism. If processes that would be applied in "Status Quo improved" will be standardized, then this mechanism could be qualified as "Standardized System of Access/Disclosure (SSAD)". I acknowledge that the Team has agreed on "centralized gateway approach" and works on this assumption. But as a theoretical model "decentralized - status Quo improved" has a justification to exist within defined parameters of our task. I do not insist on retaining of this option in the initial report, but just wanted to explain the reason behind putting the option in the draft. JK On Tue, Dec 3, 2019 at 1:46 PM Mueller, Milton L <milton@gatech.edu> wrote:
That’s the correct way to put it, Volker. No consensus, no SSAD. Perhaps the draft report can be modified to indicate that.
--MM
*From:* Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> *On Behalf Of *Volker Greimann *Sent:* Tuesday, December 3, 2019 7:38 AM *To:* gnso-epdp-team@icann.org *Subject:* Re: [Gnso-epdp-team] Draft Initial Report
Ultimately, the "no-SSAD" "option" describes the status quo. In other words, if we as a group fail to reach consensus this is what we'll have, regardless of what we want. Maybe this can serve as encouragement to move away from extreme positions that have a rabbits chance in a snake pit to survive a consensus call...
Volker
Am 03.12.2019 um 13:26 schrieb Mueller, Milton L:
Ha, you spoiled the agreement, Brian. ;-)
If I can go so far, I suggest that the initial report indicate that we are
working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus.
_______________________________________________
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.
-- 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: Alexander Siffrin
Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358. _______________________________________________ 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.
Hi Janis, when explained like that, it actually makes sense. As far as a fallback position goes, it is not something I would rule out. Best, Volker Am 03.12.2019 um 15:09 schrieb Janis Karklins:
Dear All,
Let me explain thinking behind the "Decentralized" model. It has been mentioned during the Team conversation that "status quo improved" can not be ruled out. Today there isn't system but decentralized mechanism of sending request for private registration information disclosure. Sometimes these requests are answered, sometimes remain without reply. Improvements in the current mechanism could be done through standardization of procedures that would be applied by both - requesting entities and responding entities without changing the decentralized nature of mechanism. If processes that would be applied in "Status Quo improved" will be standardized, then this mechanism could be qualified as "Standardized System of Access/Disclosure (SSAD)". I acknowledge that the Team has agreed on "centralized gateway approach" and works on this assumption. But as a theoretical model "decentralized - status Quo improved" has a justification to exist within defined parameters of our task.
I do not insist on retaining of this option in the initial report, but just wanted to explain the reason behind putting the option in the draft.
JK
On Tue, Dec 3, 2019 at 1:46 PM Mueller, Milton L <milton@gatech.edu <mailto:milton@gatech.edu>> wrote:
That’s the correct way to put it, Volker. No consensus, no SSAD. Perhaps the draft report can be modified to indicate that.
--MM
*From:*Gnso-epdp-team <gnso-epdp-team-bounces@icann.org <mailto:gnso-epdp-team-bounces@icann.org>> *On Behalf Of *Volker Greimann *Sent:* Tuesday, December 3, 2019 7:38 AM *To:* gnso-epdp-team@icann.org <mailto:gnso-epdp-team@icann.org> *Subject:* Re: [Gnso-epdp-team] Draft Initial Report
Ultimately, the "no-SSAD" "option" describes the status quo. In other words, if we as a group fail to reach consensus this is what we'll have, regardless of what we want. Maybe this can serve as encouragement to move away from extreme positions that have a rabbits chance in a snake pit to survive a consensus call...
Volker
Am 03.12.2019 um 13:26 schrieb Mueller, Milton L:
Ha, you spoiled the agreement, Brian. ;-)
>If I can go so far, I suggest that the initial report indicate that we are
> working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus.
_______________________________________________
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.
-- 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 <http://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: Alexander Siffrin
Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
_______________________________________________ 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.
-- 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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
Indeed, makes a lot more sense. “Status quo improved” via standardization would be a better description. From: Volker Greimann <vgreimann@key-systems.net> Sent: Tuesday, December 3, 2019 9:52 AM To: Janis Karklins <karklinsj@gmail.com>; Mueller, Milton L <milton@gatech.edu> Cc: gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report Hi Janis, when explained like that, it actually makes sense. As far as a fallback position goes, it is not something I would rule out. Best, Volker Am 03.12.2019 um 15:09 schrieb Janis Karklins: Dear All, Let me explain thinking behind the "Decentralized" model. It has been mentioned during the Team conversation that "status quo improved" can not be ruled out. Today there isn't system but decentralized mechanism of sending request for private registration information disclosure. Sometimes these requests are answered, sometimes remain without reply. Improvements in the current mechanism could be done through standardization of procedures that would be applied by both - requesting entities and responding entities without changing the decentralized nature of mechanism. If processes that would be applied in "Status Quo improved" will be standardized, then this mechanism could be qualified as "Standardized System of Access/Disclosure (SSAD)". I acknowledge that the Team has agreed on "centralized gateway approach" and works on this assumption. But as a theoretical model "decentralized - status Quo improved" has a justification to exist within defined parameters of our task. I do not insist on retaining of this option in the initial report, but just wanted to explain the reason behind putting the option in the draft. JK On Tue, Dec 3, 2019 at 1:46 PM Mueller, Milton L <milton@gatech.edu<mailto:milton@gatech.edu>> wrote: That’s the correct way to put it, Volker. No consensus, no SSAD. Perhaps the draft report can be modified to indicate that. --MM From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Volker Greimann Sent: Tuesday, December 3, 2019 7:38 AM To: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] Draft Initial Report Ultimately, the "no-SSAD" "option" describes the status quo. In other words, if we as a group fail to reach consensus this is what we'll have, regardless of what we want. Maybe this can serve as encouragement to move away from extreme positions that have a rabbits chance in a snake pit to survive a consensus call... Volker Am 03.12.2019 um 13:26 schrieb Mueller, Milton L: Ha, you spoiled the agreement, Brian. ;-)
If I can go so far, I suggest that the initial report indicate that we are working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus. _______________________________________________ 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. -- 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<http://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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358. _______________________________________________ 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. -- 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<http://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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
Hi Milton, In that case I won’t “go so far” to keep our agreement intact 😊 The word “never” seems troubling to me, so if you could help me understand the last part of your last sentence a bit better please: Are you saying that even if the DPB writes to the Strawberries and says “yes, it’s possible to isolate liability for decision-making centrally with ICANN Org”, it would still be impossible for us to come to consensus on the centralized decision-making model? (ignoring how (un)likely we think that response is) Brian J. King Director of Internet Policy and Industry Affairs T +1 443 761 3726 markmonitor.com<http://www.markmonitor.com> MarkMonitor Protecting companies and consumers in a digital world From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Mueller, Milton L Sent: Tuesday, December 3, 2019 7:26 AM To: gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report Ha, you spoiled the agreement, Brian. ;-)
If I can go so far, I suggest that the initial report indicate that we are working primarily toward the “centralized” model pending crucial input from the DPB.
This is not our understanding at all. One reason I want to eliminate the “no SSAD” option is that I think it confuses the issue of centralizing requests, which can be done and can gain consensus, versus centralizing the decision maker, which I think is deeply problematic and will never gain consensus.
From: King, Brian <Brian.King@markmonitor.com>
Are you saying that even if the DPB writes to the Strawberries and says “yes, it’s possible to isolate liability for decision-making centrally with ICANN Org”, it would still be impossible for us to come to consensus on the centralized decision-making model? (ignoring how (un)likely we think that response is)
Yes, indeed. That is what I am saying. This is one reason we are not so pleased with all this kerfuffle about the EDPB. You’re putting the cart before the horse. What matters is not whether it is legally _possible_ for ICANN to magically absorb the legal responsibility of the registrars for releasing the data of their customers; what matters is whether that is _desirable_ from a policy standpoint. Legal advice or “guidance” from the EDPB has no bearing on what is the right policy, it only clarifies whether one of the policy options is feasible. We want the disclosure decision to be made as close as possible to the party who is directly accountable to the registrant, the data subject, and that’s the registrar. We believe that the legitimate interests of data requestors are served by standardizing the process, and centralizing and facilitating requests, but centralizing disclosure is going to make it into an automated rubber stamp, as I suspect you have already figured out. Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology [IGP_logo_gold block_email sig]
What he said. I would add to that my oft repeated refrain: regardless of the deal you manage to cut with the DPAs, who are doubtless aware of GAC pressure for an outcome that adds zero cost and inconvenience to law enforcement, what the Court may decide is another matter. Given the ability of individuals and civil society to take a complaint and appeal to the higher Court, not to mention the ability to launch class action suits, it would be foolish to not consider this prospect in the risk analysis we do in our policy process. Stephanie Perrin On 2019-12-03 13:28, Mueller, Milton L wrote: From: King, Brian <Brian.King@markmonitor.com><mailto:Brian.King@markmonitor.com>
Are you saying that even if the DPB writes to the Strawberries and says “yes, it’s possible to isolate liability for decision-making centrally with ICANN Org”, it would still be impossible for us to come to consensus on the centralized decision-making model? (ignoring how (un)likely we think that response is)
Yes, indeed. That is what I am saying. This is one reason we are not so pleased with all this kerfuffle about the EDPB. You’re putting the cart before the horse. What matters is not whether it is legally _possible_ for ICANN to magically absorb the legal responsibility of the registrars for releasing the data of their customers; what matters is whether that is _desirable_ from a policy standpoint. Legal advice or “guidance” from the EDPB has no bearing on what is the right policy, it only clarifies whether one of the policy options is feasible. We want the disclosure decision to be made as close as possible to the party who is directly accountable to the registrant, the data subject, and that’s the registrar. We believe that the legitimate interests of data requestors are served by standardizing the process, and centralizing and facilitating requests, but centralizing disclosure is going to make it into an automated rubber stamp, as I suspect you have already figured out. Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology [IGP_logo_gold block_email sig] _______________________________________________ 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.
Hello All, In my opinion, the Registrar is the worst party to be the decision maker of the data subject due to the blatant conflict of interest. The registrant will have already entered into a legal relationship with the registrar under the registrant (end user) agreement along with it being in the best interests of the registrar to not terminate the relationship with the registrant. Therefore, I hope Milton is not saying that he will hold up consensus even if the DPAs do support the isolation of centralized decision making within ICANN Org. Best regards, Jennifer ________________________________ [https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b113a1d2a61b_WIPG_LogoMark.png]<https://www.winterfeldt.law/> Jennifer Gore Internet Governance Winterfeldt IP Group 1200 17<x-apple-data-detectors://12/1>th<x-apple-data-detectors://12/1> St NW<x-apple-data-detectors://12/1>, Ste 501<x-apple-data-detectors://12/1> Washington, DC 20036<x-apple-data-detectors://12/1> jennifer@winterfeldt.law<mailto:jennifer@winterfeldt.law> +1 202 340 9631 From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces@icann.org] On Behalf Of Mueller, Milton L Sent: Tuesday, December 3, 2019 1:29 PM To: King, Brian <Brian.King@markmonitor.com>; gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report From: King, Brian <Brian.King@markmonitor.com<mailto:Brian.King@markmonitor.com>>
Are you saying that even if the DPB writes to the Strawberries and says “yes, it’s possible to isolate liability for decision-making centrally with ICANN Org”, it would still be impossible for us to come to consensus on the centralized decision-making model? (ignoring how (un)likely we think that response is)
Yes, indeed. That is what I am saying. This is one reason we are not so pleased with all this kerfuffle about the EDPB. You’re putting the cart before the horse. What matters is not whether it is legally _possible_ for ICANN to magically absorb the legal responsibility of the registrars for releasing the data of their customers; what matters is whether that is _desirable_ from a policy standpoint. Legal advice or “guidance” from the EDPB has no bearing on what is the right policy, it only clarifies whether one of the policy options is feasible. We want the disclosure decision to be made as close as possible to the party who is directly accountable to the registrant, the data subject, and that’s the registrar. We believe that the legitimate interests of data requestors are served by standardizing the process, and centralizing and facilitating requests, but centralizing disclosure is going to make it into an automated rubber stamp, as I suspect you have already figured out. Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology [IGP_logo_gold block_email sig]
Hi, while I personally like Jen very much, I find this comment and the implication of a conflict of interest immensely offensive. This insiunuation of intent to profit from illicit use is frankly outrageous. Volker Am 03.12.2019 um 23:56 schrieb Jennifer Gore:
Hello All,
In my opinion, the Registrar is the worst party to be the decision maker of the data subject due to the blatant conflict of interest. The registrant will have already entered into a legal relationship with the registrar under the registrant (end user) agreement along with it being in the best interests of the registrar to _not terminate_ the relationship with the registrant. Therefore, I hope Milton _is not saying_ that he will hold up consensus even if the DPAs do support the isolation of centralized decision making within ICANN Org.
Best regards,
Jennifer
------------------------------------------------------------------------
https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b1... <https://www.winterfeldt.law/>
*Jennifer Gore *
Internet Governance
Winterfeldt IP Group
1200 17 <x-apple-data-detectors://12/1>^th <x-apple-data-detectors://12/1> St NW <x-apple-data-detectors://12/1>, Ste 501 <x-apple-data-detectors://12/1>
Washington, DC 20036 <x-apple-data-detectors://12/1>
_jennifer@winterfeldt.law <mailto:jennifer@winterfeldt.law>_
+1 202 340 9631
*From:*Gnso-epdp-team [mailto:gnso-epdp-team-bounces@icann.org] *On Behalf Of *Mueller, Milton L *Sent:* Tuesday, December 3, 2019 1:29 PM *To:* King, Brian <Brian.King@markmonitor.com>; gnso-epdp-team@icann.org *Subject:* Re: [Gnso-epdp-team] Draft Initial Report
*From:*King, Brian <Brian.King@markmonitor.com <mailto:Brian.King@markmonitor.com>>
Are you saying that even if the DPB writes to the Strawberries and says
“yes, it’s possible to isolate liability for decision-making centrally with
ICANN Org”, it would still be impossible for us to come to consensus on
the centralized decision-making model? (ignoring how (un)likely we think
that response is)
Yes, indeed. That is what I am saying. This is one reason we are not so pleased with all this kerfuffle about the EDPB. You’re putting the cart before the horse.
What matters is not whether it is legally _possible_ for ICANN to magically absorb the legal responsibility of the registrars for releasing the data of their customers; what matters is whether that is _/desirable/_ from a policy standpoint. Legal advice or “guidance” from the EDPB has no bearing on what is the right policy, it only clarifies whether one of the policy options is feasible.
We want the disclosure decision to be made as close as possible to the party who is directly accountable to the registrant, the data subject, and that’s the registrar. We believe that the legitimate interests of data requestors are served by standardizing the process, and centralizing and facilitating requests, but centralizing disclosure is going to make it into an automated rubber stamp, as I suspect you have already figured out.
Dr. Milton L Mueller
School of Public Policy
Georgia Institute of Technology
IGP_logo_gold block_email sig
_______________________________________________ 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.
-- 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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
Volker, James and all, Volker - No need to take my input personally, I as just merely pointing out pointing out the financial economic realities and incentives of the Registrar vs Registrant contractual relationship. James - I just wanted to point out that the focus should be more on the concept of a balance test (e.g. cost vs benefit) and not actually a "conflict of interest". Regards, Jennifer Gore From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces@icann.org] On Behalf Of Volker Greimann Sent: Wednesday, December 4, 2019 7:52 AM To: gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report Hi, while I personally like Jen very much, I find this comment and the implication of a conflict of interest immensely offensive. This insiunuation of intent to profit from illicit use is frankly outrageous. Volker Am 03.12.2019 um 23:56 schrieb Jennifer Gore: Hello All, In my opinion, the Registrar is the worst party to be the decision maker of the data subject due to the blatant conflict of interest. The registrant will have already entered into a legal relationship with the registrar under the registrant (end user) agreement along with it being in the best interests of the registrar to not terminate the relationship with the registrant. Therefore, I hope Milton is not saying that he will hold up consensus even if the DPAs do support the isolation of centralized decision making within ICANN Org. Best regards, Jennifer ________________________________ <https://www.winterfeldt.law/>[https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b113a1d2a61b_WIPG_LogoMark.png]<https://www.winterfeldt.law/><https://www.winterfeldt.law/> Jennifer Gore Internet Governance Winterfeldt IP Group 1200 17<x-apple-data-detectors://12/1>th<x-apple-data-detectors://12/1> St NW<x-apple-data-detectors://12/1>, Ste 501<x-apple-data-detectors://12/1> Washington, DC 20036<x-apple-data-detectors://12/1> jennifer@winterfeldt.law<mailto:jennifer@winterfeldt.law> +1 202 340 9631 From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces@icann.org] On Behalf Of Mueller, Milton L Sent: Tuesday, December 3, 2019 1:29 PM To: King, Brian <Brian.King@markmonitor.com><mailto:Brian.King@markmonitor.com>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] Draft Initial Report From: King, Brian <Brian.King@markmonitor.com<mailto:Brian.King@markmonitor.com>>
Are you saying that even if the DPB writes to the Strawberries and says “yes, it’s possible to isolate liability for decision-making centrally with ICANN Org”, it would still be impossible for us to come to consensus on the centralized decision-making model? (ignoring how (un)likely we think that response is)
Yes, indeed. That is what I am saying. This is one reason we are not so pleased with all this kerfuffle about the EDPB. You’re putting the cart before the horse. What matters is not whether it is legally _possible_ for ICANN to magically absorb the legal responsibility of the registrars for releasing the data of their customers; what matters is whether that is _desirable_ from a policy standpoint. Legal advice or “guidance” from the EDPB has no bearing on what is the right policy, it only clarifies whether one of the policy options is feasible. We want the disclosure decision to be made as close as possible to the party who is directly accountable to the registrant, the data subject, and that’s the registrar. We believe that the legitimate interests of data requestors are served by standardizing the process, and centralizing and facilitating requests, but centralizing disclosure is going to make it into an automated rubber stamp, as I suspect you have already figured out. Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology [IGP_logo_gold block_email sig] _______________________________________________ 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. -- 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<http://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: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
Hi Volker, If I can assist, no such insinuation was intended as to you, nor any entity or group in the EPDP. We know that you are of the highest moral caliber. I find this portion of the Wikipedia article on conflict of interest to be helpful, “The existence of such conflicts is an objective fact, not a state of mind, and does not in itself indicate any lapse or moral error.” (https://en.wikipedia.org/wiki/Conflict_of_interest) All, The IPC has concerns based on this concept: “A conflict of interest exists if the circumstances are reasonably believed (on the basis of past experience and objective evidence) to create a risk that a decision may be unduly influenced by other, secondary interests, and not on whether a particular individual is actually influenced by a secondary interest.” (Id.) Our past experience (https://www.markmonitor.com/mmblog/commentary/gdpr-and-the-impact-on-brand-p...) shows that registrars ignore or deny 87% of data requests we think they should have honored. So, we reasonably believe that registrars’ decision making around “reasonable access” under the Temporary Specification is being influenced by other interests. Some registrar interests that are in conflict (objectively) with providing access are: a) operational efficiency; b) GDPR penalties; and c) future customer business. a) Operational efficiency has been addressed by Phase 1 Recommendation 18 which requires registrars to respond, removing the conflict of operational efficiency that could be gained by ignoring requests. b) The risk of GDPR penalties cannot be avoided regardless of who makes disclosure decisions. c) The conflict of future customer business is the biggest remaining addressable conflict. Registrars have a financial interest in future customer business, and this interest is objectively in conflict with registrars’ interest in providing information about their customers. This conflict is largely eliminated by shifting decision making to ICANN. While registrars stand to lose customers to other registrars if the market perceives them as being too likely to reveal customer data, ICANN’s position both as a nonprofit and as the sole coordinator of the DNS means that their ~$0.25 per domain interest is far more insulated from this conflict than the contracted parties’ interest in future customer business. So, without attributing motivations to any party or group, we submit that the economic realities show centralized decision making to be a better approach from a conflict of interest perspective. Brian J. King Director of Internet Policy and Industry Affairs T +1 443 761 3726 markmonitor.com<http://www.markmonitor.com> MarkMonitor Protecting companies and consumers in a digital world From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Volker Greimann Sent: Wednesday, December 4, 2019 7:52 AM To: gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] Draft Initial Report Hi, while I personally like Jen very much, I find this comment and the implication of a conflict of interest immensely offensive. This insiunuation of intent to profit from illicit use is frankly outrageous. Volker Am 03.12.2019 um 23:56 schrieb Jennifer Gore: Hello All, In my opinion, the Registrar is the worst party to be the decision maker of the data subject due to the blatant conflict of interest. The registrant will have already entered into a legal relationship with the registrar under the registrant (end user) agreement along with it being in the best interests of the registrar to not terminate the relationship with the registrant. Therefore, I hope Milton is not saying that he will hold up consensus even if the DPAs do support the isolation of centralized decision making within ICANN Org. Best regards, Jennifer ________________________________ <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=2oCvCtc51t_4NIP95zDnwoFM-N5Gta-f2bUt3Df3vUE&e=>[https://daks2k3a4ib2z.cloudfront.net/59358b8cf7332631232417e8/595fb59d73c5b113a1d2a61b_WIPG_LogoMark.png]<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=2oCvCtc51t_4NIP95zDnwoFM-N5Gta-f2bUt3Df3vUE&e=><https://urldefense.proofpoint.com/v2/url?u=https-3A__www.winterfeldt.law_&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=2oCvCtc51t_4NIP95zDnwoFM-N5Gta-f2bUt3Df3vUE&e=> Jennifer Gore Internet Governance Winterfeldt IP Group 1200 17<x-apple-data-detectors://12/1>th<x-apple-data-detectors://12/1> St NW<x-apple-data-detectors://12/1>, Ste 501<x-apple-data-detectors://12/1> Washington, DC 20036<x-apple-data-detectors://12/1> jennifer@winterfeldt.law<mailto:jennifer@winterfeldt.law> +1 202 340 9631 From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces@icann.org] On Behalf Of Mueller, Milton L Sent: Tuesday, December 3, 2019 1:29 PM To: King, Brian <Brian.King@markmonitor.com><mailto:Brian.King@markmonitor.com>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] Draft Initial Report From: King, Brian <Brian.King@markmonitor.com<mailto:Brian.King@markmonitor.com>>
Are you saying that even if the DPB writes to the Strawberries and says “yes, it’s possible to isolate liability for decision-making centrally with ICANN Org”, it would still be impossible for us to come to consensus on the centralized decision-making model? (ignoring how (un)likely we think that response is)
Yes, indeed. That is what I am saying. This is one reason we are not so pleased with all this kerfuffle about the EDPB. You’re putting the cart before the horse. What matters is not whether it is legally _possible_ for ICANN to magically absorb the legal responsibility of the registrars for releasing the data of their customers; what matters is whether that is _desirable_ from a policy standpoint. Legal advice or “guidance” from the EDPB has no bearing on what is the right policy, it only clarifies whether one of the policy options is feasible. We want the disclosure decision to be made as close as possible to the party who is directly accountable to the registrant, the data subject, and that’s the registrar. We believe that the legitimate interests of data requestors are served by standardizing the process, and centralizing and facilitating requests, but centralizing disclosure is going to make it into an automated rubber stamp, as I suspect you have already figured out. Dr. Milton L Mueller School of Public Policy Georgia Institute of Technology [IGP_logo_gold block_email sig] _______________________________________________ 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<https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gnso-2Depdp-2Dteam&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=JmMJFmohprJCiaM7ehguXuLBkAu6AP4qimCMCAQq-7Y&e=> _______________________________________________ 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<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_policy&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=yegRKmbaDcSSOeF3Jpo6pYfYaSHmnjtxReflfyneKHg&e=>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_tos&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=fkOOayUxCIQe6TUS72OST0X2J6egkoC01eJ5uYzaoCo&e=>). 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. -- 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<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.key-2Dsystems.net&d=DwMDaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6-G-OrQlND3NyHHAEV7467PIEDFT6iSY04bhf8QzSOI&s=BiTK6RF5aq4FgtTRz3-nPvd53PK2K8_hwBaDzxjQfcw&e=> Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835 CEO: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.
Brian wrote: Some registrar interests that are in conflict (objectively) with providing access are: a) operational efficiency; MM: would be improved substantially by an SSAD with centralized requesting b) GDPR penalties MM: um, if they get penalized for disclosure, then the disclosure should not have happened, no? You might also think about the risks of concentrating all GDPR liability in a single source. c) future customer business MM: first, registrars have an interest in weeding out true bad guys as much as any of us. But from a data subject view, the impact of market discipline is a feature, not a bug. Switch it around. Would it be reasonable for advocates of end users/registrants to trust authorization providers who have NO accountability to end users? Why would NCSG ever accept that?
participants (7)
-
Caitlin Tubergen -
Janis Karklins -
Jennifer Gore -
King, Brian -
Mueller, Milton L -
Stephanie Perrin -
Volker Greimann