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Re: [gnso-dataprotection-thickwhois] 0429 draft

  • To: Don Blumenthal <dblumenthal@xxxxxxx>
  • Subject: Re: [gnso-dataprotection-thickwhois] 0429 draft
  • From: Carlton Samuels <carlton.samuels@xxxxxxxxx>
  • Date: Tue, 30 Apr 2013 10:49:52 -0500

Dear Don:
I have made some comments on yours inline.


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

On Mon, Apr 29, 2013 at 8:39 PM, Don Blumenthal <dblumenthal@xxxxxxx> wrote:

> I have attached a draft incorporating Carlton's changes and adding a
> comment to his comment, and following most of Steve's edits.
> I realize that I am violating the "deal with only what is" caveat, but I
> do want to address the draft RAA. The proposed amendments concerning
> privacy conflict do apply only to collection and retention. However, two
> other sections might apply.
> 3.2.1 Alternate Data Elements has a number of change related to registrars
> and registries being able to specify, with ICANN approval, publication of
> a set of Whois data elements that is not the norm. A question might be
> raised whether such an agreement could be used to limit what is published
> if the Rr and Ry agree about data protection issues. I think that such an
> argument would be a stretch, especially since the new language strikes me
> as more of a clarification rather than an amendment.

+1.  In addition, it appears designed to accommodate developments as
outlined in the Consensus Policies and Temporary Policies Specifications

> 3.3.1 Port 43 services are now required from registrars only in thin
> registries. For the sake of argument, and noting that I blanked on why we
> talked about Port 43 on a call, could we conclude that data protection
> levels would be different in thin vs thick registries?

Yes, I think you're right here.

> If so, should we
> mention the potential amendment in a footnote?

Yes, to telegraph that we noticed and for clarity.

> I will send this version to Mikey, with a note that we have some pending
> issues that will be resolved by next week. I'm not sure that we have
> enough likely callers to make a call worthwhile this week. I will call in
> if anybody wants to participate in a working session concerning a new
> draft that may appear magically tomorrow night or Monday morning. However,
> I will ask only for a phone line rather than have a formal subteam call. I
> hope that the ATRT gods aren't cringing.
> Don
> On 4/29/13 7:17 PM, "Metalitz, Steven" <met@xxxxxxx> wrote:
> >Don and colleagues,
> >
> >The attached document contains three or four small edits that are
> >reflected in my notes of our most recent call but that did not make it
> >into Don's 4/23 revised draft. It also corrects a few typos.
> >
> >With regard to the point reflected in Don's embedded comment on the next
> >to last page:  I don't think we need any more detailed analysis in this
> >paper of the changes included in the proposed 2013 RAA released last
> >week.   I say that for three reasons: first, the new proposed RAA
> >provision that Marika excerpted in an earlier e-mail deals only with
> >conflicts with respect to collection or retention of data (and extends
> >well beyond Whois data), and does not address conflicts with respect to
> >publication of Whois data:  these remain subject to the existing
> >procedure that is cited in Don's draft, even if the new RAA language is
> >adopted unchanged.  Second, by its nature anything in the RAA applies
> >only to registrars; and the move from thin to thick Whois -- our
> >assignment --  is a change in obligations for registries only.  It's
> >correct that treatment of this issue is relevant to our broader
> >recommendation that occupies the last few pages of the draft, but to me
> >this distinction underscores that this recommendation may in fact take us
> >beyond our remit.  Finally, purely as a practical matter, the text of the
> >new RAA will not become final until June at the earliest, and we
> >certainly don't want to delay this report, as part of the overall
> >contribution to the Working Group's work product, for another month or
> >two.
> >
> >Thanks again to Don for an excellent job in pulling together the
> >disparate views.
> >
> >Can we move this up to the next (full WG) level this week?
> >
> >Steve Metalitz
> >

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