[Public Comments] Call for Volunteers for NCSG Comment on Draft PTI FY21-24 Strategic Plan

[Mueller, Milton L]

That’s an interesting comment, James. Possible to elaborate more? I know you’ve been following PTI more closely than I have.

My understanding is that PTI keeps track of names, numbers and protocols. I don’t understand how there would be much of a data protection risk in its protocol numbering role. A protocol port after all is not a natural person and doesn’t have PII. I do know a lot about its IP address/numbering role. PTI/IANA just hands large blocks of IPv6 numbers to the RIRs (IPv4 blocks having run out years ago), and these blocks are not associated with specific users.  It is the RIRs, not PTI, actually maintain the registration database (address whois), so it is hard to see any issues there.

But, open to further elaboration.
--MM

From: james at icann.guru <lists at icann.guru>
Sent: Sunday, May 24, 2020 12:19 PM
To: Mueller, Milton L <milton at gatech.edu>; ncsg-discuss at listserv.syr.edu
Subject: Re: [Public Comments] Call for Volunteers for NCSG Comment on Draft PTI FY21-24 Strategic Plan

PTI has more data exposure in its other roles than it does in its naming role, I would not discount those when looking at the strategic plan.

---
James Gannon

On 5/24/2020 5:12:37 PM, Mueller, Milton L <milton at gatech.edu<mailto:milton at gatech.edu>> wrote:
We have to be careful here.

It sounds like the PTI statement is saying that by shielding Whois data from indiscriminate public access, privacy laws and regulations are “undermining trust” in registries and registrars. This is nonsense. Compliance with privacy protections and setting up accountable mechanisms for disclosing protected data actually dramatically increases trust in the system.

Whoever is running PTI should NOT be trying to oppose or undermine specific policy positions developed in the ICANN EPDP. Our comments should call this out.

If on the other hand they are warning us against jurisdictional fragmentation, it might be a more legitimate concern. In other words, jurisdictional fragmentation could undermine the ICANN/PTI regime for global DNS governance by making different government have different rules and regulations. We would be very supportive of that but the way it is phrased I think we are talking about the first meaning (bring back the old Whois) and not the second meaning (maintain global governance of DNS). After all, the problem with jurisdictional fragmentation is not that it undermines trust but that it de-globalizes DNS governance.

If they are really concerned about jurisdictional fragmentation they should be criticizing efforts by the trademark and IPR interests to engage in geographic differentiation of our rules governing registration data, and criticizing the US Congress for entertaining legislation proposals that would regulate ICANN in US jurisdiction to enable the old, open Whois.



From: NCSG-Discuss <NCSG-DISCUSS at LISTSERV.SYR.EDU<mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU>> On Behalf Of Raphael Beauregard-Lacroix
Sent: Friday, May 22, 2020 8:15 PM
To: NCSG-DISCUSS at LISTSERV.SYR.EDU<mailto:NCSG-DISCUSS at LISTSERV.SYR.EDU>
Subject: Re: [Public Comments] Call for Volunteers for NCSG Comment on Draft PTI FY21-24 Strategic Plan

Hi Tomslin,

Thanks for jumping in!

If I understand you correctly, your point is that the risk evoked here is that of conflicting data protection rules? I agree that this is a risk somewhere out there, but I don't quite make the link between a hypothetical "hard" conflict of laws and the trust of the community in PTI; would you have some language to suggest, either to add or modify what is in the comment already?

Have a nice day,

On Fri, May 22, 2020 at 7:52 PM Tomslin Samme-Nlar <mesumbeslin at gmail.com<mailto:mesumbeslin at gmail.com>> wrote:
Thanks for the draft comment Raphael. Much appreciated!

In the comment regarding "evolving  data  privacy  regulation  landscape  may  have  impacts  on  the  level  of transparency  for  the  IANA  registries,  which  may  erode  trust  and  accountability" being a risk to  Maintain  stakeholders’  trust  that  IANA  is  the  proper  home  for  enabling global  interoperability  through  unique  identifier  coordination,
you wrote ".....to imply, for example, that data protection policies (including those seemingly developed by the community in the context of the Expedited Policy Development Process) may adversely affect “transparency,” “trust,” or “accountability,” represents a value judgement. This is problematic because PTI is not the final arbiter when it comes to the implementation of those values into the policies; the community is."

In my opinion, I think it is fair for PTI to put that as risk, understanding that risk is a function of probability and impact. What they are saying there in my view is the fact that there is potential for different jurisdictional regulations to affect their ability to maintain stakeholders' trust.

Cheers,
Tomslin


On Mon., 11 May 2020, 23:58 Raphael Beauregard-Lacroix, <rbeauregardlacroix at gmail.com<mailto:rbeauregardlacroix at gmail.com>> wrote:
Hi all

I have drafted a comment. Comments, suggestions, edits are welcome. The strategic plan itself is quite short so feel free to have a look too!

Let's give it a week here so that the PC also have ample time for review.

Have a nice day,

On Mon, Apr 20, 2020 at 7:34 PM Rafik Dammak <rafik.dammak at gmail.com<mailto:rafik.dammak at gmail.com>> wrote:
Hi all,

PTI just published a public consultation on Draft PTI FY21-24 Strategic Plan and asking for input. We commented previously on PTI budget and operating plan and so it is important for us to review this strategic plan. You can find here all the details here : https://www.icann.org/public-comments/draft-pti-fy21-24-strategic-plan-2020-04-20-en

I created this google doc to be used during the drafting and accessible to all in order to kick off the discussion and comments: https://docs.google.com/document/d/1yjqC4fh-X9ISzJQWcxxwE75fHrNmnRuF93lCaweBjck/edit

Please let me offline if you want to volunteer to participate in drafting the NCSG comment, join the drafting team and collaborating with finance committee .

You can find previous public comments submitted by NCSG in this wiki page https://community.icann.org/display/gnsononcomstake/Public+Comments+-+2020 and listing those who drafted them or volunteered.

Best Regards,

Rafik Dammak

NCSG Policy Committee Chair
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