[APAC-Discuss] ICANN proposed EWG - APRALO views?

Carlton Samuels carlton.samuels at gmail.com
Mon Jul 29 20:44:34 UTC 2013

Thanks very much for laying this out Holly.  Much obliged.


Carlton A Samuels
Mobile: 876-818-1799
*Strategy, Planning, Governance, Assessment & Turnaround*

On Mon, Jul 29, 2013 at 7:19 AM, Holly Raiche <h.raiche at internode.on.net>wrote:

> Hi Everyone
> Those of you who were in Durban would have heard the presentation Carlton
> and I did on the Initial report of the Expert Working Group on what is
> called an Aggregated Registrants Data Service. (ARDS).  Essentially, the
> idea would be to have a repository of Whois data.  It is the repository
> that holds unauthorised data, verifies the data and then provides access to
> that data - on a 'gated' basis (members of the public have access to
> limited data, registered users have access to more data that is relevant to
> the use they will have for that data).  The steps are:
>  •Registrar collects registrant data – gTLD registry. gTLD registries
> hold authoritative data
> •ARDS (or other repository) as non-authoritative repository of all all
> collected data elements
> •Requestors apply for access to data – obtain access to
> non-authoritative, or special cases, authoritative data
> •ARDS repository provides validation of data, handling and auditing
> access, handling complaints and imposing penalties for inappropriate access
> At this stage, the ARDS suggestion is at the concept state. The Expert
> Working Group is seeking feedback of what people think of the idea - of
> whether to proceed with development of a more detailed proposal - with
> feedback due by mid August. (For the full proposal, go to the ICANN site
> and put EWG report in the search function).
> Carlton, EVan, Rinalia and I spent some time after the presentation
> discussing what we thought of the proposal - in light of two things:  the
> fact that the RAA and related documents have just been passed by the Board
> and have not been given time to see if they will improve issues like access
> to Whois, and the accuracy of Whois data while embedding privacy
> protections.
> After that discussion, I made some dot point notes on what I think we were
> all saying.
> *Concerns ALAC has had with the RAA, and in particular, Whois Accuracy
> (reflected in final WHois Report)*
> *-         inaccuracy of Whois data *
> *-         aligned with it, unenforceable requirements on registrars*
> *-         complete failure of compliance*
> *-         abuse of privacy/proxy*
> *-         lack of accreditation process for privacy/proxy service*
> *** ***
> *Changes to the RAA and accompanying documents*
> *-         Applaud many of the changes including*
> *-         Stronger obligations on registrars for verification *
> *-         Stronger accuracy requirements*
> *-         Stronger language  for enforcement*
> *-         At least a skeleton framework for privacy/proxy services –
> noting lack of details*
> *-        *
> *Concerns with June changes and related issues*
> *-         With compliance – will have an even bigger task – many new
> gTLDs, new metrics etc so resources already stretched*
> *-         Don’t know outcome of audit – and what action will be taken*
> *-         Still a requirement for open access for all Whois data –
> unless is hidden behind a privacy/proxy service – so doesn’t recognise
> graduated needs to Whois data*
> *-         Still some concerns with RAA language*
> * *
> *Response to  EWG proposal*
> *-         RAA changes haven’t been given a chance to work – BUT*
> *-         It addresses many issues*
> *-         Compliance – right now little if any faith in current
> department but concerns if moved – power to enforce? Resources to enforce*
> *-         Does allow gated access to data*
> *-         Would provide mechanism for protection of privacy –
> recognising the outstanding issues of who can be protected, for what, and
> who has access*
> *-         In general – welcome the concept and welcome that it
> potentially addresses issues – but are concerns (as above)*****
> So please - Carlton and I would appreciate any feedback on the proposal.
>  Is it worth proceeding with development of the concept?
> Holly
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