[ALAC] Analysis of WHOIS AoC RT Recommendations.

[Alan Greenberg]

Hi Holly, thanks for this.

Although I don't disagree with the substance of what you say, I am 
afraid that it is a bit late (or a bit early) to be saying it. The 
current statement under discussion is solely identifying the 
recommendations what do or do not, in the opinion of ALAC, require 
GNSO policy development prior to Board action. Part of what you 
suggest was implicitly in the statement the ALAC approved during its 
teleconference last week. Perhaps that statement could have included 
more details, but the feeling at the time was that it needed to be 
short and to the point.

I am sure that there will be additional opportunities to comment (or 
we could use our prerogative of speaking to the Board at any time) 
and these ideas should be fully fleshed out and made as appropriate.

Alan

At 03/09/2012 12:50 AM, Holly Raiche wrote:
>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>_______________________________________________
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