[ALAC] Analysis of WHOIS AoC RT Recommendations.

[Holly Raiche]

Hi Alan

First of all, thanks for the time you have spent on this.  I would support an ALAC response going to the Board on implementation of the Final Final Whois report - but I'd use the occasion for a very strong ALAC response.  There are details in the text of the recommendations that go further than the recommendations (and your table) suggest, and we should spell them out and urge their implementation ASAP.

For example:
under Recommendation One, the suggestions that we support include:
- establishment of a high level Committee, with the CEO at the head, to oversee the implementation of the recommendations
- encouragement of the adoption of at least test beds for appropriate protocols (we should acknowledge that some technical work is already being done)

Under Recommendation 3 - Outreach, specific constituencies are mentioned - going out to, apart from trade marks, privacy groups, other stakeholders.  We should say that many of the relevant stakeholders listed are within the ALSs and we can provide/assist in that outreach

Under Recommendation 4 - Compliance recommendations include:
- transparency of resourcing and structure
- open reporting and accountability - overseen by the high level committee
- adequate resourcing = noting that it has been understaffed and under resourced and has struggled for organisational priority
- need for follow up on the NORC report on data accuracy - particularly support for the adoption of the suggested target of a reduction by 50% within 12 months of the reduction in inaccurate Whois data (either substantially or wholly inaccurate using the NORC tests) - and a further reduction by 50% in a further 12 months
- publication of data accuracy reports
(Garth has a lot of rather frightening material on compliance issues and we should say that Compliance must become a high priority)

Under Recommendation 11 Internic
This is about the possibility of Internic as involved in a more accessible Whois.  Maybe here, we repeat our concern that the .com agreement did not contain a requirement for a thick Whois

In summary, Recommendation 14 for a Detailed and Comprehensive Plan must include all the elements of the Final Final Report's recommendations that can be implemented without a PDP.

Finally, we should acknowledge that some work is being done now, including the technical stuff, and the RAA negotiations (that should hopefully, address some of the RAA issues).  And we should acknowledge that there are some matters that will need to be addressed through a PDP - specifically, for example, the problems ALAC identified in clause 3.7.8 and the difficulty it raises in compliance.  But as much as possible should be done ASAP.   

Holly



On 03/09/2012, at 11:24 AM, Alan Greenberg wrote:

> You will recall that at its last meeting, the ALAC unanimously approved a statement to the Board reiterating its position that all 16 recommendations be implemented, and stressed that several were very important and clearly did not require any prior GNSO policy development. That ALAC statement can be found at http://tinyurl.com/ALAC-WHOIS-Advice.
> 
> Based on further discussions, and in light of a controversy that has arisen in the GNSO, it was suggested that the ALAC explicitly identify which recommendations do not require any prior policy development, and which might required GNSO policy development.
> 
> I had already done a brief review looking at which recommendations might require policy development. I have since revised this and present it to you here.
> 
> In summary, of the 16 recommendations, 12 do not require GNSO policy development, 3 *might* require policy development, but that would depend on work carried out over the coming months and years, and 1 does require policy development by the GNSO along with the rest of the community, but in my opinion, does not require a formal PDP.
> 
> The detailed analysis is attached. The report with the recommendations in detail can be found at http://www.icann.org/en/about/aoc-review/whois/final-report-11may12-en.pdf.
> 
> It is essential that this analysis reach the Board before the Board Workshop scheduled for September 12-13.
> 
> I am not sure if Olivier wants to hold a formal vote on this, or for the ALAC to just reach consensus, but regardless, the first step if for anyone who does not agree with this analysis to speak up.
> 
> Alan
> <Recs-PolicyAnalysis.pdf>_______________________________________________
> ALAC mailing list
> ALAC at atlarge-lists.icann.org
> https://atlarge-lists.icann.org/mailman/listinfo/alac
> 
> At-Large Online: http://www.atlarge.icann.org
> ALAC Working Wiki: https://community.icann.org/display/atlarge/At-Large+Advisory+Committee+(ALAC)