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

Thu May 28 15:31:12 EEST 2020

There is also the possibility that they read somewhere that IP addresses are PI, which of course they are when assigned (but not when in block allocations).   Stupid....but....well, Milton and Amr are both on the epdp so I need not explain to them..
Stephanie
PS fascinating discussion and great work guys!

Sent from my iPhone

> On May 28, 2020, at 15:43, Mueller, Milton L <milton at gatech.edu> wrote:
> 
> 
> Interesting, so protocol registries are including contact info. For who, the developer? OK, so I gotta withdraw the claim that it doesn’t happen ;-)
> But it does seem unnecessary to have that info unshielded, or published without consent, and I am still not buying the idea that bringing these practices into compliance with data protection somehow undermines trust in PTI’s role. Are they implying that if someone else did the protocol registry it would not have the same problem?
>  
>  
> From: James Gannon <lists at icann.guru> 
> Sent: Wednesday, May 27, 2020 4:57 PM
> To: Mueller, Milton L <milton at gatech.edu>
> Cc: NCSG-DISCUSS at listserv.syr.edu
> Subject: Re: [Public Comments] Call for Volunteers for NCSG Comment on Draft PTI FY21-24 Strategic Plan
>  
> Hey Milton
> Some of the protocol registries do include full contact details for individuals to whom things are delegated. On mobile so can’t grab the all the references right now but they are there, AAA as the first example https://www.iana.org/assignments/aaa-parameters/aaa-parameters.xhtml#Claudio_Lordello
> 
> Sent from my iPhone
> 
> 
> On 27 May 2020, at 21:49, Mueller, Milton L <milton at gatech.edu> wrote:
> 
> 
> Tomslin
> Thanks for finding this out. But I am convinced that whoever said IANA publishes registries with PII is living in a different world than you and me. Can anyone give me an example of how an IPv6 address block allocation to an RIR contains PII? A TLD entry in the root zone? And don’t get me started about protocol port numbers….
>  
> I really think someone in PTI is pursuing a tendentious ideological agenda based on false conflation of different types of registries and it needs to be challenged.
>  
> Dr. Milton L Mueller
> Georgia Institute of Technology
> School of Public Policy
> <image002.png>
>  
>  
>  
> From: Tomslin Samme-Nlar <mesumbeslin at gmail.com> 
> Sent: Monday, May 25, 2020 11:43 PM
> To: Mueller, Milton L <milton at gatech.edu>
> Cc: NCSG-DISCUSS at listserv.syr.edu
> Subject: Re: [Public Comments] Call for Volunteers for NCSG Comment on Draft PTI FY21-24 Strategic Plan
>  
> @Milton, @Raphael, all,
>  
> In an attempt to find whether PTI meant shielding whois data from indiscriminate access undermines trust in their services or if they meant jurisdictional fragmentation of privacy laws undermines legitimacy of PTI's services,  I went and listened to the webinar on this topic. The link to the recording  is below and it is covered between 13:00 and 13:47 of the recording. This is what I got from PTI's president's comments, I quote:
>  
> ".... in recognition that a lot of the business that IANA does is publishing public datasets....some of these are registers of allocations we've made. These registries, depending on the type of registry, contains things like PII....If the regulation is such that we are unable to complete our mission successfully, then our ability to do our job will be compromised and this might erode trust and accountability in the services we provide"
>  
> It therefore looks to me like what they meant in the document was the former and it also means they're confirming they do indeed deal with PII in protocol, numbers and names functions publications.
> I thought this might help give some more clarity to our comment.
>  
> https://icann.zoom.us/rec/play/7pUuJe-sqzk3G4DBsASDVvR6W9W9Kfqs0ykd-KFcnU-2U3AFMFr0ZuFBNuVfCHlhqY88Tlio0WeNEuXf?continueMode=true
> 
> Cheers,
> Tomslin
>    
>  
> On Mon., 25 May 2020, 02:12 Mueller, Milton L, <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> On Behalf Of Raphael Beauregard-Lacroix
> Sent: Friday, May 22, 2020 8:15 PM
> To: 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> 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> 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> 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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