RE: [gnso-thickwhoispdp-wg] missing recommendation in 7.1

["Metalitz, Steven" <met@xxxxxxx>]

I support Don's observations on both these points.  In my view Avri's post 
greatly exaggerates the significance of intervening legal developments in the 
years  since one of the largest thin registries made the transition to thick 
without any problems with respect to privacy. 

Steve

-----Original Message-----
From: owner-gnso-thickwhoispdp-wg@xxxxxxxxx 
[mailto:owner-gnso-thickwhoispdp-wg@xxxxxxxxx] On Behalf Of Don Blumenthal
Sent: Monday, September 23, 2013 9:17 AM
To: Avri Doria; Thick Whois
Subject: Re: [gnso-thickwhoispdp-wg] missing recommendation in 7.1


Avri,

Attitudes and arguments have changed since the .org transition but what 
regulatory changes have occurred in the European context? None of the major 
frameworks are different except the OECD guidelines, and the new version went 
into effect only a few weeks ago. I question whether anybody knows how the 
changes might affect what we're talking about. That needs a legal analysis in 
the first instance, not a policy one.

And to put it perhaps more gently than was expressed before, I'm tired of the 
recent snooping disclosures being waved around to make political points. They 
have nothing to do with Whois records.  I also think it's open to question on 
how many folks really care about what has been disclosed about government 
spying. In fact, a disturbing number seem to think that the practices in the 
US, and similar ones in other countries, were acceptable. Policy wonks aren't 
representative samples.

Don



On 9/22/13 12:20 PM, "Avri Doria" <avri@xxxxxxx> wrote:

>
>Hi,
>
>The .org example is somewhat dated by intervening world events including:
>
>- Regulatory changes, especially in European context to protect privacy 
>have occurred since the .org conversion. Since the days when people's 
>private information could be displayed and reused by anyone for any 
>purpose whatsoever, regulatory infrastructures have been created 
>limiting such use.  We are just beginning to understand the 
>implications of these new privacy regimes that require the protection 
>of personal data and which require that data only be used for the 
>purposes for which it was collected.
>
>-  The crimes against global privacy that have been recently revealed 
>that show that lax standards and disregard for the human right of 
>privacy have resulted, at the very least, in a global concern for 
>establishing pervasive privacy protection.
>
>I do not mean the denigrate .org or its transition in any way, but its 
>transition occurred in a simpler time when we just did not know any 
>better concerning the importance of privacy rights.  We need to make 
>sure that ICANN policy on gTLDs and private data display are in keeping 
>with current Human Rights best practices.  As we are the GNSO, our way 
>of doing that involves issues reports and PDPs.
>
>thanks
>
>avri
>
>On 22 Sep 2013, at 11:41, Rick Wesson wrote:
>
>> Is it not reasonable to mention that a large TLD was transitioned 
>>from thick to thin with zero measured impact in the transfer of all 
>>.ORG contacts to the US jurisdiction. 5 million domains at the time 
>>represented the 2nt or 3rd largest TLD in the world.
>>
>> Looking at transfers between registrar under .com there literally 
>>millions of domains per week that preform this same legal acrobatics.
>>
>> Given all the domain registrar transfers over the last 10 years one 
>>could argue that more domains have preformed this legal jurisdiction 
>>gymnastics than are currently active in com/net. Thats a very large 
>>number that will be difficult to ignore.
>>
>> No one seemed to notice that the activity or mobility of a 
>>jurisdiction that a registrants's whois moves around a lot over a domains 
>>lifecycle.
>>We should be capable of noting historical and current activity within 
>>our report on this observation.
>>
>> -rick
>>
>>
>>
>>
>> On Sun, Sep 22, 2013 at 6:46 AM, Mike O'Connor <mike@xxxxxxxxxx> wrote:
>> hi Steve,
>>
>> i realized that i didn't really respond to your whole argument with 
>>my reply.  i'm working my way through Lyme's Disease or Ehrlichiosis 
>>(nobody is quite sure which) and some days my energy level is a little 
>>lower -- your note caught me on one of those days.  my apologies for 
>>that.
>>
>> i think that Section 5 *does* support the "legal review" modification 
>>being proposed.  here are the paragraphs from Section 5 i would put 
>>forward to back that argument -- the paragraphs immediately preceding 
>>the language in my 2) suggestion.  here's the quote -- it's the four 
>>paragraphs immediately preceding the Conclusions section you're 
>>referring to:
>>
>>
>>         "However, the fact that the WG has not seen analyses or 
>>objections from the contracted party community does not prove a lack 
>>of problems. In addition, data protection and privacy laws and 
>>regulations change over time so any analyses from the past might need 
>>to be revisited periodically. RSEPs (Registry Services Evaluation 
>>Panel) initiated by .cat and .tel suggest that they have identified 
>>data protection and privacy legal issues that they considered valid 
>>even if no formal government action was initiated.  While registrars 
>>are required under the Registrar Accreditation Agreement to obtain 
>>registrants¹ consent to uses made of data collected from them, whether 
>>registrants are aware of the full ramifications of data publication, 
>>legal or real, might be questioned, and local rules concerning 
>>coercive contract provisions conceivably could come into play.
>>
>>         "The WG has made every effort to examine thin vs. thick 
>>registry models in a broad sense. However, any requirement that all 
>>registries use the thick model will require that existing thin 
>>registries move to thick environments. This situation will raise 
>>concerns that, while limited in the long run, are significant given 
>>the numbers of domains and registrants involved. The WG expects that 
>>data transfers will be in volumes unprecedented in Whois operations 
>>and urges that increased information systems and protections are put 
>>in place, which are appropriate to handle the volumes.
>>
>>         "Some registrations may have occurred based on a registrant¹s 
>>consideration of local rules governing a registrar or registry.  In 
>>that event, registrants¹ data protection expectations will be affected 
>>when publication of Whois data moves to a registry that is in a 
>>different jurisdiction from the relevant registrar.  Thorough 
>>examination must be given to the extent to which data protection 
>>guarantees governing a registrar can be binding on a registry. Should 
>>data protections in the jurisdiction of a registrant, registrar, or 
>>registry control? Should registry or registrar accreditation 
>>agreements contain language that specifies whose protection environment 
>>applies?
>>
>>         "Again, these questions must be explored in more depth by 
>>ICANN Staff, starting with the General Counsel¹s Office, and by the community.
>>As an added benefit, analyses concerning change of applicable laws 
>>with respect to transition from a thin to a thick environment also may 
>>prove valuable in the event of changes in a registry¹s management, 
>>presumably an increasing likelihood given the volume of new gTLDs on the 
>>horizon."
>>[note, this is the paragraph i'm proposing to move down into the 
>>immediately-following Conclusions section you're quoting from]
>>
>>
>>
>> your #1 citation says "The WG finds that requiring thick Whois for 
>>all gTLD registries does not raise data protection issues that are 
>>specific to thin v. thick Whois."  that quote refers to the topic of 
>>data protection, not privacy -- the sub-team went to a lot of trouble 
>>to separate those two issues and so i don't think that point is 
>>relevant to this discussion.
>>
>> your #2 citation says "There are currently issues with respect to 
>>privacy related to Whois and these will only grow in the future.....
>>None of these issues *SEEM* to be related to whether a thick or thin 
>>Whois model is being used. " [emphasis mine]  which doesn't rule out 
>>the possibility of a legal review, especially given the (i think) 
>>consensus view that we don't really have the expertise on this WG to 
>>evaluate the nuances of those issues.
>>
>> your #3 citation says "So although privacy issues may become a 
>>substantive issue in the future, and should certainly be part of the 
>>investigation of a replacement for Whois, it is not a reason not to 
>>proceed with the PDP WG recommending thick Whois for all."  i'm not 
>>sure i follow how a legal review (which seems prudent in any case) 
>>contradicts that argument.
>>
>> Steve, is your concern that the legal review could be used to *block* 
>>the transition to thick Whois?  if that's the case, i share your 
>>concern.  but i view it more in the "identify and mitigate risks"
>>department and hope that others would too.  i would be open to 
>>clarifying that language if folks felt the need.
>>
>> regarding your point on the "undermine at the last minute" argument 
>>-- i think i mentioned this on the call.  i as the Chair bear the 
>>responsibility for not testing more aggressively for consensus *much* 
>>earlier in the process.  most of my frustration on the last call was 
>>with myself for allowing this issue to slide to the end.  but the fact 
>>is, we don't have consensus yet and we need to work on getting there.
>>
>> to that end i've pulled my little 3-point recommendation into a Word 
>>document and include it into this post for people to contemplate and 
>>edit.  i decided it was time to move the text into something that can 
>>be red-lined rather than using the pretty-limited text-only email format.
>>
>> thanks all for a spirited discussion -- let's contemplate this some 
>>more and see if we can get to a place where we can all live with the 
>>result.
>>
>> thanks,
>>
>> mikey
>>
>>
>>
>>
>>
>>
>> On Sep 20, 2013, at 11:38 AM, "Metalitz, Steven" <met@xxxxxxx> wrote:
>>
>> >
>> > Mikey,
>> >
>> > I do not share your assumption that the transition to thick Whois
>>must be delayed pending a legal review.   This is entirely unsupported
>>by the findings of our report.
>> >
>> > 1.  "The WG finds that requiring thick Whois for all gTLD 
>> > registries
>>does not raise data protection issues that are specific to thin v. 
>>thick Whois. "
>> >
>> > 2.  "There are currently issues with respect to privacy related to
>>Whois and these will only grow in the future..... None of these issues 
>>seem to be related to whether a thick or thin Whois model is being used.
>>"
>> >
>> > 3.  "So although privacy issues may become a substantive issue in 
>> > the
>>future, and should certainly be part of the investigation of a 
>>replacement for Whois, it is not a reason not to proceed with the PDP 
>>WG recommending thick Whois for all."
>> >
>> > All these quotes are from the conclusion to section 5.5 of our
>>report.  I believe this text represents a consensus of the 
>>participants in the privacy subgroup of our WG.  Don can confirm or correct 
>>this.
>> >
>> > I encourage everyone to re-read section 5.5.  It makes very clear
>>that, based on over a decade of  experience with thick gTLD 
>>registries, including the successful transition of one of the largest 
>>gTLD registries from thin to thick; the complete absence of any legal 
>>challenges during that time period to the operation of such registries 
>>on privacy grounds;, and the support of registrars and registries --- 
>>the entities with the greatest incentive to take seriously the potential
>>legal exposure involved  --   for the thick model,  that there is no
>>privacy- or data protection-based reason to delay adoption and 
>>implementation of the thick Whois requirement.
>> >
>> > This conclusion reflects the thoroughly discussed and fully
>>negotiated view of those who participated actively in this WG over the
>>past year.   It should not be set aside or undermined at the last minute.
>> >
>> > I continue to disagree as well with your point 3 for the reasons
>>already thoroughly discussed on this list.
>> >
>> > Could you explain what is the difference, in your view, between a
>>"little-r recommendation" in section 7.3 and a "big-R recommendation" 
>>in section 7.1, especially since you propose that both take the form 
>>of a statement that "We recommend....".
>> >
>> > Steve
>> > -----Original Message-----
>> > From: owner-gnso-thickwhoispdp-wg@xxxxxxxxx
>>[mailto:owner-gnso-thickwhoispdp-wg@xxxxxxxxx] On Behalf Of Mike 
>>O'Connor
>> > Sent: Friday, September 20, 2013 11:58 AM
>> > To: Avri Doria
>> > Cc: Thick Whois
>> > Subject: Re: [gnso-thickwhoispdp-wg] missing recommendation in 7.1
>> >
>> > i think maybe i need to put all the stuff in one post.
>> >
>> > 1) we put a big-R recommendation to do the legal review in 7.1.
>>here's the language that Volker proposed with some rough draft 
>>"sequence" language in brackets.
>> >
>> >> We recommend that the ICANN Board request an independent legal
>>review to be undertaken [before transition to thick whois] on the 
>>privacy implications of a transfer of registrant data between 
>>jurisdictions.
>> >
>> > 2) we beef up the body of the report to support that recommendation
>>-- the language is already there, i just think it ought to be moved 
>>down into a more recommendation-focused paragraph.  again rough-draft 
>>"sequence" language in brackets.
>> >
>> >> page 30:  "Again, these questions must be explored in more depth 
>> >> by
>>ICANN Staff [before transition to thick whois], starting with the 
>>General Counsel's Office, and by the community. As an added benefit, 
>>analyses concerning change of applicable laws with respect to 
>>transition from a thin to a thick environment also may prove valuable 
>>in the event of changes in a registry's management, presumably an 
>>increasing likelihood given the volume of new gTLDs on the horizon."
>> >
>> > 3) we put a version of your little-r recommendation in section 7.3
>> >
>> >> The WG  discussed many of the issues involved in moving from 
>> >> having
>>a registration currently governed under the privacy rules by one 
>>jurisdiction in a thick whois to another jurisdiction, the 
>>jurisdiction of the Registry in a thick whois.  The WG did not feel it 
>>was competent to fully discuss these privacy issues and was not able 
>>to fully separate the privacy issues involved in such a move from the 
>>general privacy issues that need to be resolved in Whois.  there was 
>>also concern with intersection with other related Privacy issues that 
>>ICANN currently needs to work on.  The Working group therefore makes 
>>the following
>>recommendation:
>> >>
>> >> . We recommend that the ICANN Board request a GNSO issues report 
>> >> to
>>cover the issue of Privacy as related to WHOIS and other related GNSO 
>>policies.
>> >
>> >
>> >
>> >
>> > On Sep 20, 2013, at 9:24 AM, Avri Doria <avri@xxxxxxx> wrote:
>> >
>> >>
>> >> Hi,
>> >>
>> >> All lovely ideas, but they don't meet the need to put the privacy
>>issues on the front burner.
>> >>
>> >> avri
>> >>
>> >> On 20 Sep 2013, at 09:24, Mike O'Connor wrote:
>> >>
>> >>> [hijacking this thread back to its original topic]
>> >>>
>> >>> hi Avri,
>> >>>
>> >>> i, for one, think turnabout on the way to consensus is one of the
>>very best things about ICANN.  thanks Avri
>> >>>
>> >>> here's language describing that legal review as it stands (this 
>> >>> is
>>the last paragraph of Discussion section of 5.5 Data Protection
>> >>>
>> >>> page 30:  "Again, these questions must be explored in more depth 
>> >>> by
>>ICANN Staff, starting with the General Counsel's Office, and by the 
>>community. As an added benefit, analyses concerning change of 
>>applicable laws with respect to transition from a thin to a thick 
>>environment also may prove valuable in the event of changes in a 
>>registry's management, presumably an increasing likelihood given the 
>>volume of new gTLDs on the horizon."
>> >>>
>> >>> i *think* that's the only place it shows up in the current draft,
>>which means that while we worked hard on the language, it's not really 
>>a recommendation right now and kindof buried down in the details.  
>>it's also vague on the sequencing -- but i have been presuming that 
>>the legal review would have to happen before the conversion and would 
>>be comfortable clarifying that.
>> >>>
>> >>> from a report-drafting standpoint if we pursue this direction, i
>>think we'd want to do a few minor revisions to provide support for 
>>that big-R recommendation that's being proposed.
>> >>>
>> >>> - clarify that sequence
>> >>>
>> >>> - move that paragraph from the "Discussion" section of 5.5 down 
>> >>> to
>>the "Conclusions" section to provide stronger underpinnings for the 
>>recommendation
>> >>>
>> >>> all pretty easy to do from a mechanical report-drafting point of
>>view, if the group agrees on that approach.
>> >>>
>> >>> good work.  carry on,
>> >>>
>> >>> mikey
>> >>>
>> >>>
>> >>>
>> >>>
>> >>> On Sep 19, 2013, at 10:47 AM, Avri Doria <avri@xxxxxxx> wrote:
>> >>>
>> >>>>
>> >>>> Hi,
>> >>>>
>> >>>> Forgive me for doing this bit of turnabout: is this legal review
>>something that would occur before the thick whois for incumbent 
>>registries was put into effect?
>> >>>>
>> >>>> At first blush, if this was combined with a 7.3. recommendation
>>for a full Issues report, I might be able to accept it and convince 
>>the NCSG that this was a good compromise.
>> >>>>
>> >>>> thanks
>> >>>>
>> >>>> avri
>> >>>>
>> >>>>
>> >>>> On 19 Sep 2013, at 11:14, Volker Greimann wrote:
>> >>>>
>> >>>>> Hi all,
>> >>>>>
>> >>>>> I still find Avri's proposed language too broad, so I tried my
>>hand at a quick rewrite. Probably still needs a little fiddling, but 
>>more in the direction what I could support, although putting this into
>>7.1 is a bit iffy to me.
>> >>>>> The WG discussed many of the issues involved in moving from
>>having a registration currently governed under the privacy rules by 
>>one jurisdiction in a thin whois to another jurisdiction, the 
>>jurisdiction of the Registry in a thick whois.  The WG did not feel it 
>>was competent to reach a final conclusion on these issues involving 
>>international privacy laws.
>> >>>>> The Working group therefore makes the following recommendation:
>> >>>>>
>> >>>>> . We recommend that the ICANN Board request an independent 
>> >>>>> legal review to be undertaken on the
>>privacy implications of a transfer of registrant data between 
>>jurisdictions.
>> >>>>> Reasons: If we could not find ourselves competent to decide a
>>small matter like the transfer of private data, how can we expect 
>>another PDP to tackle an even broader issue of privacy issues 
>>surrounding WHOIS in general? For the purposes of this WG, the 
>>determination that we were unable to reach a final conclusion on could 
>>and should be resolved by independent counsel.
>> >>>>>
>> >>>>> While a new PDP on WHOIS and privacy issues is certainly
>>something worth considering and something I would welcome, I do not 
>>feel that this WG needs to make that recommendation as it would be 
>>much broader than the smaller issue we were tasked to tackle.
>> >>>>>
>> >>>>> Volker
>> >>>>>
>> >>>>>> Hi,
>> >>>>>>
>> >>>>>> For me this needs to be a Recommendation (7.1, big R), not an
>>extra consideration.  This issue was within the purview of the group 
>>and the group bailed on it for lack of capability.  Fine, then lets step and
>>recommend that those that have the capability do so.    In this age of
>>world attention on privacy issues, I can't beleive we are still 
>>dancing around the point.
>> >>>>>>
>> >>>>>> I am currently working on getting the NCSG to endorse this.  
>> >>>>>> As
>>the alternate chair of the NCSG Policy committee I beleive this is 
>>something that will be supported by the NCSG.  I will personally 
>>submit a minority position and work to get the NCSG to endorse it, if 
>>this recommendation is not included in 7.1.  For myself at this point, 
>>I will reject the entire report without this, as the report is 
>>incomplete without this as a primary Recommendation.  To my mind NCSG 
>>would be shirking it responsibilities if we let this report go out 
>>without such a recommendation.
>> >>>>>>
>> >>>>>> Incidentally, my impression from the list discussion was that
>>there was support, but that wording needed changing.  It was changed.
>> >>>>>>
>> >>>>>> I understand that there are those who may be playing divide 
>> >>>>>> and
>>conquer games behind the scenes, claiming that my position will hurt 
>>NCSG's reputation.  I have bcc'e d the NCSG on this note so that they 
>>themselves can determine if it is reputation damaging.  There are 
>>others who are are cynically claiming that I am going against the 
>>bottom-up model by insisting on privacy considerations.  I reject those 
>>claims.
>> >>>>>>
>> >>>>>> avri
>> >>>>>>
>> >>>>>>
>> >>>>>>
>> >>>>>> On 19 Sep 2013, at 10:25, Mike O'Connor wrote:
>> >>>>>>
>> >>>>>>
>> >>>>>>> hi all,
>> >>>>>>>
>> >>>>>>> i may have been the culprit here.  Avri, my interpretation of
>>the desultory conversation on the list was that there *wasn't* much 
>>support for the idea.  and then when you didn't show up on last week's 
>>call to pitch/push it, i forgot to bring it up.  my bad -- sorry about 
>>that.
>> >>>>>>>
>> >>>>>>> let's try to have a vigorous conversation about this on the
>>list, and drive to a conclusion on the call next week.
>> >>>>>>>
>> >>>>>>> Avri, you and i had a one-to-one email exchange about this 
>> >>>>>>> and
>>i suggested that this recommendation might fit better, and be more 
>>widely accepted, if it was in the privacy and data protection part of 
>>our report (Section 7.3).  could you give us an indication of whether 
>>acceptance of this version of the recommendation is required?  in more 
>>casual terms, is there any wiggle room here?  i think it would be 
>>helpful for the rest of the group to know the framework for the 
>>conversation.
>> >>>>>>>
>> >>>>>>> carry on folks,
>> >>>>>>>
>> >>>>>>> mikey
>> >>>>>>>
>> >>>>>>>
>> >>>>>>> On Sep 18, 2013, at 6:39 PM, Avri Doria <avri@xxxxxxx>
>> >>>>>>> wrote:
>> >>>>>>>
>> >>>>>>>
>> >>>>>>>> Hi,
>> >>>>>>>>
>> >>>>>>>> I was disappointed to not see the recommendation for the
>>Issues report included in 7.1.    I thought we had discussed it on this
>>list and thee had been little opposition, though there was some.  I
>>cannot support this report with a strong recommendation for follow on
>>work on the Privacy issues.  And, contrary to what others may beleive, I
>>do not see any such work currently ongoing in ICANN.  I think it i s
>>unfortunate that we keep pushing off this work and are not willing to
>>face it directly.  I beleive I have the support of others in the NCSG,
>>though the content of a minority statement has yet to be decided on.
>> >>>>>>>>
>> >>>>>>>> While still somewhat inadequate, I am ready to argue for going
>>along with consensus on this document if the following is included in
>>7.1:
>> >>>>>>>>
>> >>>>>>>>
>> >>>>>>>> The WG  discussed many of the issues involved in moving from
>>having a registration currently governed under the privacy rules by one
>>jurisdiction in a thick whois to another jurisdiction, the jurisdiction
>>of the Registry in a thick whois.  The WG did not feel it was competent
>>to fully discuss these privacy issues and was not able to fully separate
>>the privacy issues involved in such a move from the general privacy
>>issues that need to be resolved in Whois.  there was also concern with
>>intersection with other related Privacy issues that ICANN currently
>>needs to work on.  The Working group therefore makes the following
>>recommendation:
>> >>>>>>>>
>> >>>>>>>> . We recommend that the ICANN Board request a GNSO issues
>>report to cover the issue of Privacy as related to WHOIS and other
>>related GNSO policies.
>> >>>>>>>>
>> >>>>>>>>
>> >>>>>>>>
>> >>>>>>>> Thanks
>> >>>>>>>>
>> >>>>>>>> avri
>> >>>>>>>>
>> >>>>>>>>
>> >>>>>>>>
>> >>>>>>>
>> >>>>>>> PHONE: 651-647-6109, FAX: 866-280-2356, WEB:
>> >>>>>>> www.haven2.com
>> >>>>>>> , HANDLE: OConnorStP (ID for Twitter, Facebook, LinkedIn, etc.)
>> >>>>>>>
>> >>>>>>>
>> >>>>>>
>> >>>>>
>> >>>>>
>> >>>>> --
>> >>>>> Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
>> >>>>>
>> >>>>> Mit freundlichen Grüßen,
>> >>>>>
>> >>>>> Volker A. Greimann
>> >>>>> - Rechtsabteilung -
>> >>>>>
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