I think these are really important questions Andrew. Unfortunately when we talk about privacy and data control, we often use idioms that are technologically out of date (eg video surveillance, which conjures up mental images of video tapes that have not been used in 15 years). To be clear, we need to talk about control of data elements. Fortunately, despite a lot of FUD to the contrary, the EU data protection authorities have focused on data controllers and data processors, and we have good documents with summaries for those concepts. They have not changed with the new regulation, so they are still valid. If I understand RDAP correctly, it would permit duly authorized data access from anywhere, to elements that could be scattered. This would match current data mining techniques. The problem, as I see it, and I beg to be corrected if I am wrong, is how do we manage a remote authorization scheme to individual data elements, if indeed some data is held by the registrar, some by the registry, and some (outside ICANN's remit, but an answer to LEA demands) by the ISP? Cheers Stephanie On 2016-07-16 1:00, Andrew Sullivan wrote:
Thanks, Stephanie, for the quick issue list. There's one thing that I want to draw out here so that we can keep it foremost when thinking of issues:
On Sat, Jul 16, 2016 at 12:05:10AM -0400, Stephanie Perrin wrote:
* Where the RDS (whether a central database or federated or completely disaggregated) resides becomes important for law enforcement access. This "where data resides" issue is bound to vex us, no matter what kind of policy we come up with. But it's really important to keep in mind that the different styles of system design will yield very different properties.
In the taxonomy I offered before (http://mm.icann.org/pipermail/gnso-rds-pdp-wg/2016-June/000951.html), models I and V have a clear since answer to, "Where does the data reside?" because they have a single database backing them up. In models II-IV, however, the answer to, "Where does the data reside?" is actually not entirely meaningful. There are multiple places where the data are, and for data with respect to any given domain name each datum might be in a different place. (Indeed, part of the design of RDAP is precisely to make such arrangements easier to deal with.)
It is therefore better to try to find a way, consistent with all of the various requirements documents, to answer some other questions. I think these might be helpful in building use cases:
1. For any given datum, who has control of and access to the datum?
2. For any given datum, what are the conditions under which the datum ought to be accessible?
3. For any given set of related data, how can it be accessed?
Notice that answering (3) will provides use cases for data access, whereas (1) and (2) provide for limit conditions on how and when use cases might be apply.
I hope these framing questions are helpful in figuring out which use cases we can bring to bear on requirements.
Best regards,
A