Statement: EPDP recommendations/WHOIS privacy

[farzaneh badii]

Yeah but it didn’t have to be included in this policy which has disclosure
provisions.

On Thu, Feb 14, 2019 at 9:59 AM Stephanie Perrin <
stephanie.perrin at mail.utoronto.ca> wrote:

> Basically the contracted parties appear to be agreeing that registries
> should be thin, unless the need for data transfer has been proven.  Some of
> those registries have legitimate needs to verify some data.  They ought to,
> of course, do a review under the GDPR and limit the personal data...but
> that is up to them as controllers.
>
> Stephanie
> On 2019-02-14 09:55, farzaneh badii wrote:
>
> Hi Kathy
>
> Yes sorry I wanted the statement be brief. The additional data elements
> are what new gtld registries ask for from the registrants. For example
> .Lawyer might ask for a bar (law not liquor)  license. As the new
> gtlds expand these additional data elements can be hundreds of personal
> info such as driver's license, identification cards etc.
>
> I am going to elaborate on this statement and the recommendations in the
> Google doc.
>
>
> Farzaneh
>
>
> On Thu, Feb 14, 2019 at 9:45 AM Kathy Kleiman <kathy at dnrc.tech>
> <kathy at dnrc.tech> wrote:
>
>> 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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>>
> --
Farzaneh
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