<html><head><meta http-equiv="Content-Type" content="text/html charset=us-ascii"></head><body style="word-wrap: break-word; -webkit-nbsp-mode: space; -webkit-line-break: after-white-space;"><div><br><div><div>On 21 Apr 2018, at 8:20 am, Alan Greenberg <<a href="mailto:alan.greenberg@mcgill.ca">alan.greenberg@mcgill.ca</a>> wrote:</div><br class="Apple-interchange-newline"><blockquote type="cite">
<div>
This comment has been circulated within the ALAC and At-Large, but there
has not been sufficient time to decide to what extent if it fully
accepted. As such, it is being submitted here purely on my personal
behalf.<br><br>
===============<br><br>
There has been significant community comment that this proposal was
originally (and to some extent still is) a creature of the BC. <br><br>
I APPLAUD that the BC/IPC have taken the initiative to do this! I and
many of us have been saying for several months (certainly starting before
the Abu Dhabi meeting) that the accreditation model is an absolute key to
moving forward. <br><br>
The BC/IPC have done something and put it down on paper. Bravo!<br><br>
I think this model is a great start.<br><br>
I see problems with it, but we need to start the discussion somewhere.
What do I see as problematic?
<ul>
<li>I think the provision to give access to "All users", while
it would be nice for me personally, is more than a bit loose. We are
going to need something MUCH stronger to grant access over and above the
other accredited channels.
</li><li>A single tier is not sufficient. There should be more granularity
based on the uses. Perhaps we could start with this single and improve
later, but my preference would be to use the use-cases we have already
built to provide more than one few tier (ie more than just a) thin WHOIS,
or b) ALL of the data.)
</li><li>I look forward to the work that the document says the SSAC is doing
regarding credentialization.
</li><li>I STRONGLY support the
<a href="https://community.icann.org/download/attachments/84213851/APWG-GDPR-Accreditationplancomments-5April2018-0001.pdf?version=1&modificationDate=1524004586000&api=v2">
comments from the Anti-Phishing Working Group (APWG)</a>. These comments
make the model more effective and implementable. The only one I find
possible questionable related to funding the accreditation process.
Although I would prefer that it is an integral part of the DNS and WHOIS
(and thus funded by ICANN through its normal sources), I would not want
to see implementation delayed over this issue.
</li></ul></div>
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