Thank you, Sarah!
Yuko
From:
Sarah Wyld <swyld@tucows.com>
Date: Friday, August 4, 2023 at 5:01 AM
To: Yuko Yokoyama <yuko.yokoyama@icann.org>, "Kapin, Laureen" <LKAPIN@ftc.gov>, "LEWIS-EVANS, Christopher" <Christopher.Lewis-Evans@nca.gov.uk>, "gnso-epdpp2-smallteam@icann.org" <gnso-epdpp2-smallteam@icann.org>
Cc: Eleeza Agopian <eleeza.agopian@icann.org>
Subject: RE: [GNSO-EPDPP2-SmallTeam] [Ext] [O] Item 2 - Language provided toRar/Ry to ensure checkbox is used properly
I think Laureen’s changes are great and really help the material to be understandable for non-lawyer readers.
--
Sarah Wyld, CIPP/E
Policy & Privacy Manager
Pronouns: she/they
swyld@tucows.com
Dear Laureen,
Thank you for the suggested language. I wanted to see if Sarah had feedback, as I recall her sharing concerns about the original language not written in a simple, layman’s term way. If no feedback from Sarah or others, we will incorporate
these new suggested languages in our system.
Please note, I will be on my holiday until mid-August. I am CC’ing Diana Middleton here from the ICANN org’s project team so she can follow up as necessary in my absence.
Thank you,
Yuko
From: "Kapin, Laureen" <LKAPIN@ftc.gov>
Date: Wednesday, July 26, 2023 at 9:22 AM
To: Yuko Yokoyama <yuko.yokoyama@icann.org>, "LEWIS-EVANS, Christopher" <Christopher.Lewis-Evans@nca.gov.uk>, "gnso-epdpp2-smallteam@icann.org" <gnso-epdpp2-smallteam@icann.org>
Cc: Eleeza Agopian <eleeza.agopian@icann.org>
Subject: RE: [Ext] [O] Item 2 - Language provided to Rar/Ry to ensure checkbox is used properly
Dear Yuko,
Apologies for the delay. I’ve conferred with Chris and Gabe and here is our proposed “plain language” revision:
To Rrs (as shown in the screenshot):
“This request pertains to an
active ongoing Law Enforcement investigation. It is very important that you keep this request confidential so that
In order for Law Enforcement can to effectively use the data for
the identified is purpose., it is crucial that this request remains confidential.
You should not let the registrant know about The existence of this request
should not be revealed to the registrant. If your the registrars policies do not allow for confidential disclosure
to law enforcement, we ask request that you stop processing
this request be disregarded and take steps to alert the law enforcement requestor of your policy - rather than taking any action which would lead you to notifying the registrant
not process ited.”
To Requestors (slightly modified since the screenshot):
“By
c Checking this box will notify ,the Registrar
will be notified of your request for confidentiality. Please n Note that this is a voluntary system, and the participating registrars have agreed to
use make their best efforts to honor your request. This may
include volve the registrar taking certain steps appropriate measures to
follow up on comply with your request, providing you with information on the steps that can be taken, or rejecting your request without notifying the registered name holder.”
Kind regards,
Laureen Kapin
Assistant Director for International Consumer Protection
Office of International Affairs
Federal Trade Commission
lkapin@ftc.gov
From: GNSO-EPDPP2-SmallTeam <gnso-epdpp2-smallteam-bounces@icann.org>
On Behalf Of Yuko Yokoyama
Sent: Friday, July 7, 2023 11:59 AM
To: LEWIS-EVANS, Christopher <Christopher.Lewis-Evans@nca.gov.uk>; gnso-epdpp2-smallteam@icann.org
Cc: Eleeza Agopian <eleeza.agopian@icann.org>
Subject: Re: [GNSO-EPDPP2-SmallTeam] [Ext] [O] Item 2 - Language provided to Rar/Ry to ensure checkbox is used properly
Dear Chris,
My apology for not closing the loop on this end, while I did email the screenshots of the revised confidentiality language in a new email thread (posted
here).
Since the creation of the screenshots, we have further modified the language on the Requestor side to tighten the message. Please see below the current language:
To Rrs (as shown in the screenshot):
“This request pertains to an ongoing Law Enforcement investigation. In order for Law Enforcement to effectively use the data for this purpose, it is crucial that this request remains confidential. The existence
of this request should not be revealed to the registrant. If the registrars policies do not allow for confidential disclosure, we request that this request be disregarded and not processed.”
To Requestors (slightly modified since the screenshot):
“By checking this box, the Registrar will be notified of your request for confidentiality. Please note that this is a voluntary system, and the
participating registrars have agreed to make their best effort to honor your request. This may involve the registrar taking appropriate
measures to comply with your request, providing you with information on the steps that can be taken, or rejecting your request without notifying the registered name holder.”
Thank you,
Yuko
From:
"LEWIS-EVANS, Christopher" <Christopher.Lewis-Evans@nca.gov.uk>
Date: Monday, June 5, 2023 at 3:00 AM
To: Yuko Yokoyama <yuko.yokoyama@icann.org>, "gnso-epdpp2-smallteam@icann.org" <gnso-epdpp2-smallteam@icann.org>
Cc: Eleeza Agopian <eleeza.agopian@icann.org>
Subject: [Ext] [O] Item 2 - Language provided to Rar/Ry to ensure checkbox is used properly
OFFICIAL
Morning sorry for the delay on this please find the below proposed wording adjustment around the confidentiality checkbox
To rr’s
“This request relates to a Law Enforcement investigation.
To allow us to utilise the data for this purpose this request must be kept confidential and the existence of this request must not to be disclosed to the registrant. If the registrars policies do not allow for confidential disclosure
then please do not process this request. Premature notification to the registrant may constitute obstruction of an ongoing investigation”
To LEA’s
“By checking this box the Registrar will be notified of your request for confidentiality for your request from the registered name holder. This
is a voluntary system and best efforts will be taken to comply with your request, or detailing actual steps that can be carried out, or to reject your request without notifying the registered name holder.”
Many Thanks
Chris
This information is supplied in confidence by the NCA. The NCA is not listed as a Public Authority under the Freedom of Information Act 2000. Any information supplied by, or relating
to, the NCA is also subject to an absolute exemption.
It may also be subject to exemption under other UK legislation. Onward disclosure may be unlawful, for example, under data protection
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