[ALAC] GDPR Model Comments

Carlton Samuels carlton.samuels at gmail.com
Tue Jan 30 21:39:50 UTC 2018


Holly's outline comes closest to what I think is supportable from an ALAC
that is thinking globally. On the balance of reason, fact and evidence, I
would advise support for Holly's statement.

The winning hand here is how perfectly nuanced one can be. So don't forget
it is not a set piece.  Because when the usual regimes of evasions and
sophistry - like extant Handling WHOIS Conflict With National Laws
characterisations - are developed around it even crocodiles will be happy.

[BTW, the above is one reason why a single ICANN WHOIS policy is neither
strategically or operationally ideal.]

-Carlton


==============================
*Carlton A Samuels*

*Mobile: 876-818-1799Strategy, Planning, Governance, Assessment &
Turnaround*
=============================

On Tue, Jan 30, 2018 at 3:40 PM, Holly Raiche <h.raiche at internode.on.net>
wrote:

> Thanks Alan
>
> And because we did not manage to agree on a model, I have also submitted a
> statement (attached) that largely repeats what I put on the list.  And for
> those who supported other models, I would urge you to also make submissions
> on the models (I note both Christopher and Seun supported Model 3 - now you
> need to say so directly to ICANN Org
>
> Holly
>
>
>
>
> On 31 Jan 2018, at 5:33 am, Alan Greenberg <alan.greenberg at mcgill.ca>
> wrote:
>
> Regarding our deliberations on GDPR models -
> https://community.icann.org/x/HQa8B
>
> The message below says that they are not formally extending the deadline,
> but will consider new input - presuming it comes in relatively quickly.
>
> At this point, as far as I can see, I have been the only At-Large person
> to submit a personal comment, and no RALO or At-Large comments have been
> submitted.
>
> Alan
>
> From: GDPR Questions <gdpr-questions at icann.org>
> To: Evin Erdogdu <evin.erdogdu at icann.org>
> CC: Alan Greenberg <alan.greenberg at mcgill.ca>, Ariel Liang
>          <ariel.liang at icann.org>
> Subject: Re: TODAY/URGENT: At-Large Extension Request for GDPR Model
> Comments
> Date: Tue, 30 Jan 2018 18:00:07 +0000
> user-agent: Microsoft-MacOutlook/f.28.0.171108
>
> Thank you for the notes requesting an extension. As you may be aware, we
> are receiving significant input from a wide range of stakeholders over the
> past days, a full list can be found at: https://www.icann.org/
> resources/pages/gdpr-legal-analysis-2017-11-17-en and we are updating
> this continuously.
>
> Unfortunately, we are unable to provide an extension. We would encourage
> you to provide any additional input as soon as possible, and would welcome
> to hear from you how you’d like to proceed as feedback is important.
>
>
> *From: *Evin Erdogdu <evin.erdogdu at icann.org>
> *Date: *Monday, January 29, 2018 at 21:31
> *To: *GDPR Questions <gdpr-questions at icann.org>, "gdpr at icann.org" <
> gdpr at icann.org>
> *Cc: *Alan Greenberg <alan.greenberg at mcgill.ca>, Ariel Liang <
> ariel.liang at icann.org>
> *Subject: *Re: TODAY/URGENT: At-Large Extension Request for GDPR Model
> Comments
>
> Dear GDPR Staff,
>
> Has the comment period been formally extended? Please advise.
>
> Kind Regards,
> Evin
>
> *From: *GDPR Questions <gdpr-questions at icann.org>
> *Date: *Saturday, January 27, 2018 at 1:45 AM
> *To: *Evin Erdogdu <evin.erdogdu at icann.org>, "gdpr at icann.org" <
> gdpr at icann.org>
> *Cc: *Alan Greenberg <alan.greenberg at mcgill.ca>, Ariel Liang <
> ariel.liang at icann.org>
> *Subject: *Re: TODAY/URGENT: At-Large Extension Request for GDPR Model
> Comments
>
> Dear Alan, we acknowledge receipt of your request and it will be
> published.
>
>
> *From: *Evin Erdogdu <evin.erdogdu at icann.org>
> *Date: *Friday, January 26, 2018 at 15:15
> *To: *"gdpr at icann.org" <gdpr at icann.org>
> *Cc: *Alan Greenberg <alan.greenberg at mcgill.ca>, Ariel Liang <
> ariel.liang at icann.org>
> *Subject: *TODAY/URGENT: At-Large Extension Request for GDPR Model
> Comments
>
> Dear Staff,
>
> In light of the importance of the GDPR issue and the ongoing discussion
> within At-Large and elsewhere in ICANN, Alan Greenberg, ALAC Chair requests
> an extension of no less than 10 days for submission of comments.
>
>
> *Please confirm this extension request has been received. *
> Kind Regards,
>
> Evin Ashley ErdoÄŸdu
> AC/SO and Policy Support
> Internet Corporation for Assigned Names and Numbers (ICANN)
>
>
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