A very general summary of the comments that accompanied the Save Domain Privacy petition
Dear all, To various degrees each Sub Team cc¹d here has been discussing how it wishes to approach both the specific language of, as well as the additional comments that accompanied, the Save Domain Privacy petition that was signed by 10,042 people. I did a quick skim of the additional comments that were sent in as an attachment to the petition and prepared the following summary based on the initial categories used by the Save Domain Privacy organizers in their statement. Some of this may be more relevant or useful to one rather than another Sub Team, but I thought it may be helpful to send it to all of you nonetheless. For Sub Team 2 on Section 1.3.3, while there were quite a few comments that did not distinguish between personal-use domains and websites with those used for commercial purposes, there were other commenters who linked their concerns over privacy or anonymity with their specific experiences as registrants or proxy customers of domains that are used in relation to online financial transactions of one sort or other. Please see the categories below for additional details. For Sub Team 3 on Annex E, on the question of whether ³verifiable evidence² means only a court order, no commenter expressly said this is what the phrase must mean, although a few noted that disclosure should only take place upon either a court order, warrant, due process or (in one instance) ³some legal document². Several mentioned the possibility of getting a subpoena or a warrant (with a few adding that this is due process that should be obtained from legal channels, law enforcement or a government agency). Others simply noted that these are existing channels that can be used without specifying if they believed these to be the only ones. One or two mentioned the need that disclosure be made only upon ³probable cause² or ³good cause² but without specifically linking this to a court order. As such, and if I may, I don¹t think we can say that there is unequivocal support from the additional comments to the petition for one specific meaning to the term ³verifiable² (should the Sub Team or Working Group wish to go down that path). While there were numerous comments that simply stated the commenter¹s wish for privacy and/or the need to respect the right to privacy in general terms, there were also numerous commenters that tried to relate their opinions to specific concerns. Generally, the most common concerns that can be gleaned from these additional comments to the SDP petition seem to be: * Doxing/SWAT-ing and concerns about physical safety (e.g. stalking, harassment or where registrant is in an unsafe or threatening location) * Anonymity needs for certain individuals and organizations (e.g. those serving at-risk communities, targeted minorities, political and religious activists) * Lack of separation of online business presence from personal information, in some cases for cost reasons and especially for home-based or small businesses (e.g. online shop owners, freelancers, self-employed persons, writers) * Registrants who use pseudonyms and pen names for legal reasons (e.g. adult entertainers, erotica authors) * Data harvesting concerns * Spam, scams and identity theft (e.g. phishing attempts) * Other legitimate need for privacy of domain information, e.g. new product launches, business competitors, pre-launch websites I hope some at least of this is useful to your groups as you try to complete your discussions on this question and move on to reviewing the other comments. I will try to upload the document that contains all these additional comments to your respective Sub Team wiki pages if I can (it is 554 PDF pages!); in the meantime, here is the link to it in the public comment forum: http://forum.icann.org/lists/comments-ppsai-initial-05may15/pdfCL0NdiQmaL.pd f. Cheers Mary Mary Wong Senior Policy Director Internet Corporation for Assigned Names & Numbers (ICANN) Telephone: +1 603 574 4889 Email: mary.wong@icann.org
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Mary Wong