Statement: EPDP recommendations/WHOIS privacy

[farzaneh badii]

Dear All,

The Council is going to vote on the motion to approve the recommendations
of EPDP tomorrow (Thursday). We are at the final stages of our
deliberations at EPDP and it is almost done.

The council has to vote on this report (attached) as a whole and cannot
vote on recommendations separately. This makes our work a bit difficult
because we do not agree with all the recommendations. One approach would be
for NCSG councilors to approve the report but make a short statement for
our own record.

I have been discussing the concerns for a couple of weeks on this list so
there is nothing new and I hope that we can direct our councilors tomorrow
to make this statement if they can:


NCSG statement/ For GNSO Council Meeting, 14 February

Despite an unrealistic timeline, EPDP achieved its goal and delivered the
final report. We are positive about the final report and our councilors
have voted for its approval. But we are concerned with some aspects of the
report and would like to record our concerns.


   -

   The report has included additional potentially  personal and sensitive
   data elements that are “identified by Registry Operator in its registration
   policy."  There was no justifiable reason to include these additional data
   elements in the report, nor was it justifiable to formulate purposes that
   could relate to processing these additional elements.  These additional
   data elements were not included in Temp Spec either. We are concerned about
   subjecting these additional data elements to this policy and warn the ICANN
   community and domain name registrants that due to this addition even more
   sensitive and personal data might be disclosed to third parties on a global
   scale.



   -

   Data protection should be provided for all domain name registrants
   globally regardless of their location. Discriminatory treatment of domain
   name registrants and providing some with less data protection is not
   justified, especially as we are moving towards disclosing domain name
   registrants data to third parties "globally".
   -

   We believe "disclosure" of data to third parties is not an ICANN purpose
   for processing the data.


We thank the EPDP, its leadership and ICANN staff for achieving this
milestone. We hope that with this policy by cultivating a
privacy-respecting culture at ICANN, protecting the personal data of domain
name registrants becomes a norm, and not remain an exception.


Link to the statement:


https://docs.google.com/document/d/1M8M0kaQSdQD3CC1HmpSTwMIKcufCT0ekVu7yHgx_f5w/edit?usp=sharing


Comments are welcome (I think we have some hours)  but since Councilors are
going to read this statement out I give them the liberty of changing the
tone or re-doing the statement.

Best





Farzaneh
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