[ALAC] ALAC Response to Accreditation Model - due date 20 April
Alan Greenberg
alan.greenberg at mcgill.ca
Tue Apr 17 22:52:19 UTC 2018
Tijani, the data (much of it, but perhaps not
all) has proven useful and necessary for
DETECTING and IDENTIFYING the problems. It is
only after that work that registrars/registries
can be asked to take sites down.
Once a phishing site is identified, it can be
taken down *IF* the registrar agrees - some to
not! WHOIS data can lead to other domain names
that may be implicated or will be used for
phishing in the future. And it has proven very
useful for ultimately identifying the perpetrator
and not just taking down a single site.
Alan
At 17/04/2018 05:40 PM, Tijani BEN JEMAA wrote:
>Alan,
>
>Of course, we must ensure the safety and
>reliability of the DNS. Bute can you explain how
>collecting such huge amount of registrant data
>can make us sure that the DNS is safe and
>reliable? In case of unlawful harmful use, the
>registrar can immediately stop it, and this is
>true whatever the amount of data collected is.
>On the other hand, what you say is almost as if
>you say: since we know there will be criminals,
>we must surveil all the population so that we
>can catch anyone who will act badly.
>
>-----------------------------------------------------------------------------
>Tijani BEN JEMAA
>Executive Director
>Mediterranean Federation of Internet Associations (FMAI)
>Phone: +216 98 330 114
> +216 52 385 114
>-----------------------------------------------------------------------------
>
>
>>Le 17 avr. 2018 Ã 21:06, Alan Greenberg
>><<mailto:alan.greenberg at mcgill.ca>alan.greenberg at mcgill.ca> a écrit :
>>
>>I said *I* would try to add some comments
>>tonight. Add to what you had said (on Wiki now
>>that it is there). Still hope to but time running out.
>>
>>To be clear, it IS *OUR* job to make sure that
>>the DNS is safe and reliable. That is our only
>>job! Law enforcement, or anyone else that can
>>justify their need can get data only if we first collect it.
>>
>>But that is not relevant to the accreditation model as Scott says.
>>
>>At 17/04/2018 07:13 AM, Holly Raiche wrote:
>>>Hi Alan
>>>
>>>When you say ‘we can add some comments tonight’ my questions are
>>> * what comments?
>>> * and add to what?
>>>There is no link on the policy page to the accreditation model.
>>>
>>>And next - I’d have to differ on your
>>>views. Article 29 starts from basic privacy
>>>principles - as followed in over 100 countries
>>>around the globe with data protection
>>>regimes. First basic principle: only collect
>>>personal information that is necessary to do
>>>YOUR job. You don’t collect information you
>>>don’t need. Next principle: You tell the
>>>data subject why you need their personal
>>>information, and the circumstances in which
>>>that information will be shared. It is to
>>>THAT limited use and disclosure that people
>>>consent to giving their personal information.
>>>And it is in those LIMITED circumstances in
>>>which personal information is disclosed. The
>>>fact that others may want access is irrelevant.
>>>
>>>So that right away limits who gets information
>>>- and in limited circumstances only.
>>>
>>>In almost every data protection regime, law
>>>enforcement will be a circumstance in which
>>>personal information is made available. But
>>>again - not blanket permission, but in
>>>circumstances where there is a reasonable
>>>chance that illegal/harmful activity is or has
>>>taken place. And a further read suggests that
>>>access would also be given to
>>>Government/government authorised authorities
>>>as well. Two examples in Australia would be
>>>ASIC, our prudential regulator, and the ACCC,
>>>our competition and consumer watchdog. So the
>>>category of law enforcement probably extends
>>>to other regulatory/enforcement agencies -
>>>again, in situations where harm is suspected/occuring.
>>>
>>>So - far from having an outstanding lack of
>>>knowledge about the Internet and ICANN,
>>>Article 29 know exactly what is going on. And
>>>it is what now amounts to unlawful release of
>>>personal information - and not just in the EU.
>>>
>>>If there is to be any even slightly middle
>>>ground, it will be close to the model that
>>>Scott has already tested - access is possible,
>>>but to specific, accredited people and for
>>>specific situations. And it is in THAT
>>>context that the DNS will be protected. (and,
>>>as the cyber security advisor to our Prime
>>>Minister said, when asked how to make the
>>>Internet safe, replied that it isn’t possible to make it safe, only safer.)
>>>
>>>Holly
>>>
>>>
>>>
>>>
>>>
>>>
>>>On 17 Apr 2018, at 4:58 pm, Alan Greenberg
>>><<mailto:alan.greenberg at mcgill.ca>alan.greenberg at mcgill.ca > wrote:
>>>
>>>>Holly I have been travelling and am ties up
>>>>in meetings all day (Brussels time), but I
>>>>hope to add some comments later tonight.
>>>>
>>>>I caution care in interpreting the Article 29
>>>>letter. Despite some valid concerns, it shows
>>>>an astounding lack of knowledge of the
>>>>Internet and ICANN's mission. As a prime
>>>>example is their advice to just focus on our
>>>>own business and not that of others such as
>>>>law enforcement or those combatting cyber
>>>>issues. Our mission is to protect the DNS and
>>>>that includes making it reliable and safe.
>>>>But we do not have the ability to do that
>>>>ourselves and thus must provide the tools for
>>>>others to do that. If we fail, we are NOT carrying out our mission.
>>>>
>>>>This will get more interesting in coming weeks.
>>>>
>>>>Alan
>>>>
>>>>
>>>>
>>>>At 16/04/2018 07:58 PM, Holly Raiche 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->
>>>>>>>>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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>>>>>
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