Statement: EPDP recommendations/WHOIS privacy

[Kathy Kleiman]

H Farzaneh,

Tx to the amazing work of the NCSG EPDP team, and for your posting 
below./Question: can you provide us with a bit more detail about the 
"additional potentially  personal and sensitive data elements that are 
'identified by Registry Operator in its registration policy'"? //
/

/What types of elements are being discussed? /

Best and tx, Kathy

On 2/13/2019 8:13 PM, farzaneh badii wrote:
> 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

-- 
Kathy Kleiman
Visiting Scholar, Center for Information Technology, Princeton University
President (on leave), Domain Name Rights Coalition



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