[ALAC] ALAC Response to Accreditation Model - due date 20 April

Tue Apr 17 11:19:56 UTC 2018

Agreed - thank Carlton

And yes, this is all early too late, but then nothing they have said hasn’t been said before - if anyone was listening.

Holly
On 17 Apr 2018, at 6:26 pm, Carlton Samuels <carlton.samuels at gmail.com> wrote:

> In my own view the expectations by ICANN from the request to Article 29 WP folks presaged either a woeful misunderstanding of the role/function of the Article 29 WP in the EU/EC framework or the first move in a fiendishly clever ploy to get them on record for purpose.  
> 
> Because quite frankly, them fellas didn't say anything that a moderately sentient observer that is conversant with the issues and have some time in place could not have anticipated.
> 
> -Carlton
> 
> 
> ==============================
> Carlton A Samuels
> Mobile: 876-818-1799
> Strategy, Planning, Governance, Assessment & Turnaround
> =============================
> 
> On Mon, Apr 16, 2018 at 6:58 PM, Holly Raiche <h.raiche at internode.on.net> wrote:
> Folks
> 
> We are fast running out of time to develop any kind of response to the accreditation model, even though the deadline for a response has been extended to this Friday. And in the interim, ICANN has received advice from Article 29 on the Interim model. (Article 29 is an advisory Group made up of a data protection authority from each EU member state).  Their letter to ICANN, and Marby’s response, are on the home page of ICANN - and for those interested in the issue, I highly recommend reading both.  Clearly, the implications of the Article 29 letter are that the Interim Model that we did comment on still raises concerns with them.  Those concerns fall under the headings:
> Breadth of purpose - saying the proposed purposes are too widely drawn
> the link of purpose to processing - again, because the Whois data has been used does not qualify it as a purpose 
> publication of the data must be linked to the original (and narrowly defined) purpose
> any access should be limited - not blanket access
> discussion about the length of retention of data
> discussion about the transfer of data
> Accreditation (particularly important in this context) - should only be for legitimate purpose, limited to the original purpose, not blanket access, and under limited conditions
> 
> Below, I have copied in an email from Scott Hollenbeck, a long standing member of ICANN and one of those involved in the development of the RDAP (access protocol that would allow gated access to registration data) - simply because he has been involved in this issue for a long time and shows he has already worked on a technical solution to this issue - how access to data could work under GDPR.
> 
> I will try to attend as much as possible of the capacity building webinar on this issue, but have been scheduled to attend an all-day course in the Sydney CBD so may have to miss some of the discussion.  I imagine Tom will be very up to date on these issues, but I would like to have been attending the whole of the webinar myself 
> 
> In any case, if at all possible, we should be saying something.  Quite apart from the original contribution from the IPC/BC model, the NCSG and Registrars have also made comments (largely challenging the IPC/BC model). I hope we are the one constituency that doesn’t make comments - although I realise that agreement on what to say will be difficult at the best of times.
> 
> And if it isn’t too late - maybe put this issue on the ALAC policy page - and with it, links to the Article 29 letter, Marby’s response, the registrars’ response and the NCSG response (and any others I have missed - I have copies if that helps)
> 
> Holly
> 
> 
> 
> 
> 
>>>> 
>>>> Hi all.
>>>> 
>>>> After reading the Article 29 WP letter to ICANN
>>>> (awbs://www.icann.org/en/system/files/correspondence/jelinek-to-marby-
>>>> 11apr18-en.pdf), I started envisioning what process and system could
>>>> achieve GDPR compliance. What I came to is a token-based system, which
>>>> would work like this:
>>>> - Every request is analyzed by a human at an "RDS Clearinghouse". Each
>>>> request can be for a single data element (like "owner of domain X") or to
>>>> multiple data elements (like "domains owned by the same owner of domain
>>>> X"), but requests for multiple data elements are only foreseen to be
>>>> processed by contracted parties with "Search WHOIS" contract requirements.
>>>> - Clearinghouse issues a token with query parameters, data elements
>>>> authorized for response, identity of authorized party, reason for
>>>> authorization, validity (probably in the order of days), also informing
>>>> which endpoint to go to.
>>>> - Authorized party uses that token to access that endpoint, managed by the
>>>> party with most data about that element (usually a registrar).
>>>> 
>>>> Note that is not a replacement for credentialing; credentials would still
>>>> be necessary to get tokens. This is also orthogonal to discussions like
>>>> which use cases are legitimate or not, GDPR-compliant or not etc.; it's
>>>> just a more granular approach to authorization that looks more inline with
>>>> privacy-oriented guidelines including but not limited to GDPR.
>>> 
>>> Rubens, at a high level you just described how OpenID and OAuth work, except for the "Every request is analyzed by a human" part.
>> 
>> Scott,
>> 
>> I believe you are right, although most OAuth models I saw were not that granular to the point of saying "example.TLD, owner, e-mail address, valid until April 20 2018". That's not an OAuth limitation though, just common usage, and it probably could be made to work like this. 
>> And some level of asynchronous communications could even make way for a quick look human analysis. 
>> 
>> 
>> Rubens
> 
> I have this very model, with human involvement, up and running right now as part of the gTLD RDAP Pilot. All of the attributes you mentioned can be encoded as OAuth claims. The model is described in an Internet-Draft that I first wrote in 2015. Just search for “draft Hollenbeck RDAP OpenID” using your favorite search engine.
> 
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