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

[Raphael Beauregard-Lacroix]

Hi Milton, all,

Thanks, a few points you raised were already made but otherwise I added
your language to what was there.

Have a nice evening,

On Sun, May 24, 2020 at 11:54 PM Mueller, Milton L <milton at gatech.edu>
wrote:

> Raphael:
>
>
>
> I looked over the section of the report about “the evolving data privacy
> regulation landscape.” I note that it comes under the section devoted to
> “Maintain stakeholders’ trust that IANA is the proper home for enabling
> global interoperability through unique identifier coordination.”
>
>
>
> I would offer the following language as a response (feel free to copy):
>
>
>
> The evolving data privacy regulation landscape may have impacts on the
> level of transparency for the IANA registries, which may erode trust and
> accountability.
>
>
>
> Response:
>
> This purported risk is not well-defined. NCSG asks that PTI elaborate on
> it in a way that clarifies what risks it sees from “data privacy
> regulation” and how those risks have the potential to affect the IANA
> functions.
>
>
>
> In our view, PTI’s involvement with global protocol, name and number
> coordination is not directly affected by privacy laws. IANA’s engagement
> with these functions do not involve personally identifiable information
> about natural persons. While it is true that IANA’s *customers* –
> specifically, TLD registries and RIRs – may be affected by data protection
> laws and regulations, this is generally a positive thing. In our view
> privacy protections actually enhance trust and accountability on the
> internet and do not erode it. For example, the reform of DNS Whois to make
> it compliant with GDPR makes it more difficult for the data to be abused
> and ensures that those who request disclosure of that data are accountable.
> Transparency is maintained but with appropriate safeguards.
>
>
>
> There is, however, one sense in which “the evolving data privacy
> landscape” could affect stakeholders’ trust in PTI as the proper home for
> enabling global interoperability. Differences over data protection law
> among different national governments could fragment DNS or IP Address
> governance. This would indeed undermine reliance on a global coordination
> entity such as PTI.  If PTI is really concerned about jurisdictional
> fragmentation, it should add the following things to its strategic plan:
>
> a)       Develop a clearer identification of this risk
>
> b)      Support the efforts of ICANN’s EPDP to develop a globally
> applicable privacy and disclosure policy for registration data, and warn
> against efforts by certain stakeholders to engage in geographic
> differentiation of the policies.
>
> c)       Warn against efforts by national legislative bodies to impose
> geographically distinct regulations on ICANN.
>
>
>
> We look forward to further clarification of these points in the strategic
> plan.
>
>
>
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