GNSO Council Accuracy Assignment - Questions to be answered by NCSG

Poncelet Ileleji pileleji at JOKKOLABS.CO
Fri Feb 14 21:49:53 EET 2025 

+1 Farzi

Appreciated and thank you

Peace

Poncelet

On Friday, February 14, 2025, farzaneh badii <farzaneh.badii at gmail.com>
wrote:

> Hello all,
>
> Submitting the attached today to the Council today.
>
> Best regards,
>
> Farzaneh
>
>
> On Fri, Jan 31, 2025 at 4:39 AM Tomslin Samme-Nlar <mesumbeslin at gmail.com>
> wrote:
>
>> Hi all,
>>
>> Since there are no further inputs or comments, I will proceed to submit
>> what I have here to the council as NCSG response, since today is the
>> deadline for submission.
>>
>> Thanks again Farzi for your contribution to this.
>>
>> Warmly,
>> Tomslin
>>
>> On Wed, 29 Jan 2025, 07:30 Tomslin Samme-Nlar, <mesumbeslin at gmail.com>
>> wrote:
>>
>>> Hi Farzi,
>>>
>>> Thanks for the contribution. It is timely!
>>>
>>> @everyone, are there any other suggested contributions to these
>>> questions?
>>>
>>> I am also re-attaching the ICANN Org response here since it appears the
>>> previous link is now broken.
>>>
>>> Warmly,
>>> Tomslin
>>>
>>>
>>>
>>> On Tue, 28 Jan 2025 at 15:17, farzaneh badii <farzaneh.badii at gmail.com>
>>> wrote:
>>>
>>>> Thanks Tomslin. Please see my responses below:
>>>>
>>>> Farzaneh
>>>>
>>>>
>>>> On Tue, Jan 7, 2025 at 8:58 PM Tomslin Samme-Nlar <
>>>> mesumbeslin at gmail.com> wrote:
>>>>
>>>>> Hi all,
>>>>>
>>>>> If you recall, Registration data accuracy has been a topic of
>>>>> contention in the community now for a while. Those who follow the the topic
>>>>> know that the Accuracy Scoping team was paused by the council due to
>>>>> challenges of pursuing further work on accuracy, including that
>>>>>
>>>>>    1. It is unclear whether [the scenarios] would provide useful data
>>>>>    to inform the Accuracy Scoping Team’s efforts;
>>>>>    2. The scenarios are not expected to provide data as it relates to
>>>>>    identity verification of the registrant or veracity of the contact
>>>>>    information (i.e., the data belongs to the data subject);
>>>>>    3. The costs associated with a full-scale registrar audit [Scoping
>>>>>    Team Recommendation #2] may be prohibitive when taking into account the
>>>>>    relatively low level of insight the audit may yield;
>>>>>    4. ICANN does not have the authority to mandate collection of
>>>>>    nonpublic registration data necessary to conduct reviews outside of
>>>>>    auditing current contractual requirements; and
>>>>>    5. ICANN may not be able to demonstrate the purpose of some of the
>>>>>    data processing outweighs the rights of the impacted data subject.
>>>>>
>>>>> As a result, deliberations on this topic on the council was deferred
>>>>> till February and an assignment to ask ICANN Org some clarifying legal
>>>>> questions, and thereafter ask each SG/C to respond to a set of threshold
>>>>> questions that will help guide the way forward on this topic was agreed by
>>>>> the council. ICANN Org came back with their response
>>>>> <https://urldefense.com/v3/__https:/us-east-1.secure-attach.amazon.com/da78dbeb-dd4d-4f3f-96c2-1d5abfe7810b/d3fd2bca-021f-494b-957c-0c800d63f333__;!!PtGJab4!5ebsdR0WRUrjpIzUO8HekPbjqckThf0GWEiIM_7eVuzWwd4NAuc_-nt2-GqtwpE87UIulB_KPGxmS00M_1a2SSvlTw$>
>>>>> just before the December holidays.
>>>>>
>>>>> Now therefore, each SG/C is required to respond to the threshold
>>>>> questions
>>>>> <https://gnso.icann.org/sites/default/files/policy/2024/draft/draft-concept-proposal-accuracy-12sep24.pdf>
>>>>> by Friday 31 January 2025. We forgot to include it for discussion in our
>>>>> Policy meeting earlier this week. However, I request that members provide
>>>>> their input via this email thread. Once agreed, we'll forward our response
>>>>> to the Council. The questions we have to answer are in the link above but
>>>>> for convenience, I'll list them here below:
>>>>>
>>>>>    1. *What are concrete and articulable examples of what inaccurate
>>>>>    data DOES prevent or inhibit, and how does it do so?*
>>>>>
>>>>> Inaccurate domain name registrant data should be defined based on the
>>>> purpose of accuracy within the scope of ICANN's mandate: ensuring that the
>>>> registrant is 'contactable.' If the registrant cannot be reached due to
>>>> undeliverable messages caused by errors in the provided contact details,
>>>> the data should be deemed inaccurate.
>>>>
>>>>>
>>>>>    1. *What are concrete and articulable examples of what inaccurate
>>>>>    data does NOT prevent?*
>>>>>
>>>>>
>>>>>    1. *Are there specific stakeholders, industries, or sectors
>>>>>    particularly vulnerable to the effects of inaccurate registration data? If
>>>>>    so, what are they and why?*
>>>>>
>>>>> Domain name registrants can be affected by insisting on having even
>>>> more "accuracy" requirements. In order to ensure accuracy suggestions could
>>>> be made to "identify" domain name registrants which goes against the
>>>> principle of respecting anonymity should the domain name registrant want to
>>>> remain anonymous and identification of registrants can have an
>>>> adverse impact on data protection and access to domain names globally.
>>>>
>>>>
>>>>
>>>>>    1. *Given the examples provided in response to the three questions
>>>>>    above (if any), please articulate a short problem statement for accuracy.
>>>>>    The problem statement should consider:*
>>>>>       - *What is the current problem or challenge?*
>>>>>       - *What are the consequences of this problem or challenge?*
>>>>>       - *What is the ultimate objective of working on this problem or
>>>>>       challenge?*
>>>>>       - *Considering the limitations of data processing, how do you
>>>>>       propose to address this problem?*
>>>>>
>>>>> We don't believe there are many challenges facing data accuracy. There
>>>> are already requirements in place for domain name registrants to keep their
>>>> data accurate, and there is an ultimate punishment for that: losing their
>>>> domain name if they don't do so. Please refer to registrants obligation
>>>> here: https://www.icann.org/resources/pages/registration-
>>>> data-accurate-2023-11-02-en?utm_source=chatgpt.com
>>>>
>>>>>
>>>>>    1. *Is now the appropriate time to address the problem? For
>>>>>    example, some stakeholders have mentioned the implementation of NIS2 as an
>>>>>    important precursor to understanding new accuracy requirements. Should this
>>>>>    or other examples be considered prior to engaging in potential policy work?*
>>>>>
>>>>> it's crucial to remember that NIS2 is a directive, not a regulation.
>>>> Its implementation will vary across European jurisdictions, and it
>>>> shouldn't set the accuracy standard for ICANN. This is due to two key
>>>> reasons:
>>>>
>>>> 1. NIS2's provisions concerning domain names were influenced by
>>>> specific stakeholder groups, not by multistakeholder consensus.
>>>> 2. Some transposing laws (e.g., Germany) aim to identify registrants
>>>> through data accuracy to prevent fraud. However, we believe that accuracy
>>>> at ICANN should not necessitate registrant identification.
>>>>
>>>>>
>>>>>    1. *Are the ICANN org alternatives proposals worth exploring, such
>>>>>    as:*
>>>>>       - *Provision of historical audit data that measures registrars’
>>>>>       compliance with accuracy-related provisions in the RAA.*
>>>>>       - *Engagement with contracted parties and ccTLD operators on
>>>>>       developments in European policymaking regarding registration data accuracy.*
>>>>>    2. *What are the limitations of the ICANN proposals? Why should or
>>>>>    should they not be pursued?*
>>>>>    3. *What other possibilities can be explored to move our work on
>>>>>    Accuracy forward?*
>>>>>
>>>>> I look forward to your contribution to these questions.
>>>>>
>>>>> Warmly,
>>>>> Tomslin
>>>>>
>>>>>
>>>>>
>>>>> ---------- Forwarded message ---------
>>>>> From: Feodora Hamza via council <council at icann.org>
>>>>> Date: Thu, 12 Dec 2024 at 23:11
>>>>> Subject: [council] Re: Follow-up GNSO Council Accuracy Assignment
>>>>> To: DiBiase, Gregory <dibiase at amazon.com>, council at gnso.icann.org <
>>>>> council at gnso.icann.org>
>>>>>
>>>>>
>>>>> Dear Councilors,
>>>>>
>>>>>
>>>>>
>>>>> due to technical issues, please see accuracy assignment attached and
>>>>> linked below.
>>>>>
>>>>> Accuracy Assignment: https://gnso.icann.org/sites/
>>>>> default/files/policy/2024/draft/draft-concept-proposal-
>>>>> accuracy-12sep24.pdf
>>>>>
>>>>>
>>>>>
>>>>> Kind regards,
>>>>>
>>>>> Feodora Hamza
>>>>>
>>>>>
>>>>>
>>>>> *From: *"DiBiase, Gregory via council" <council at icann.org>
>>>>> *Reply to: *"DiBiase, Gregory" <dibiase at amazon.com>
>>>>> *Date: *Thursday, 12 December 2024 at 20:57
>>>>> *To: *"council at gnso.icann.org" <council at gnso.icann.org>
>>>>> *Subject: *[council] Follow-up GNSO Council Accuracy Assignment
>>>>>
>>>>>
>>>>>
>>>>>    - *Attachments protected by Amazon: *
>>>>>    - Answer to the GNSO questions on accuracy.pdf
>>>>>    [us-east-1.secure-attach.amazon.com]
>>>>>    <https://urldefense.com/v3/__https:/us-east-1.secure-attach.amazon.com/da78dbeb-dd4d-4f3f-96c2-1d5abfe7810b/d3fd2bca-021f-494b-957c-0c800d63f333__;!!PtGJab4!5ebsdR0WRUrjpIzUO8HekPbjqckThf0GWEiIM_7eVuzWwd4NAuc_-nt2-GqtwpE87UIulB_KPGxmS00M_1a2SSvlTw$> |
>>>>>
>>>>>    - ATT00001.txt [us-east-1.secure-attach.amazon.com]
>>>>>    <https://urldefense.com/v3/__https:/us-east-1.secure-attach.amazon.com/da78dbeb-dd4d-4f3f-96c2-1d5abfe7810b/94d6cb3e-3ab2-446c-a385-9c201a9cffc9__;!!PtGJab4!5ebsdR0WRUrjpIzUO8HekPbjqckThf0GWEiIM_7eVuzWwd4NAuc_-nt2-GqtwpE87UIulB_KPGxmS00M_1ZAKmAJaA$> |
>>>>>
>>>>>
>>>>> Amazon has replaced the attachments in this email with download links.
>>>>> Downloads will be available until January 11, 2025, 19:56 (UTC+00:00). Tell
>>>>> us what you think [amazonexteu.qualtrics.com]
>>>>> <https://urldefense.com/v3/__https:/amazonexteu.qualtrics.com/jfe/form/SV_ehuz6zGo8YnsRKK__;!!PtGJab4!5ebsdR0WRUrjpIzUO8HekPbjqckThf0GWEiIM_7eVuzWwd4NAuc_-nt2-GqtwpE87UIulB_KPGxmS00M_1Zzdd6ztA$>
>>>>>
>>>>> For more information click here [docs.secure-attach.amazon.com]
>>>>> <https://urldefense.com/v3/__https:/docs.secure-attach.amazon.com/guide__;!!PtGJab4!5ebsdR0WRUrjpIzUO8HekPbjqckThf0GWEiIM_7eVuzWwd4NAuc_-nt2-GqtwpE87UIulB_KPGxmS00M_1ZzNkqBbQ$>
>>>>>
>>>>> Dear Councilors,
>>>>>
>>>>>
>>>>>
>>>>> I am following up on the attached email from ICANN Org in which they
>>>>> provided their input on the accuracy assignment.  On 25 October, we shared
>>>>> the proposed accuracy assignment, which included questions for ICANN org
>>>>> and the community.
>>>>>
>>>>>
>>>>>
>>>>> Now that ICANN org has provided responses to the Council’s questions,
>>>>> we are now sending the remaining questions in the attached proposal to
>>>>> interested SG/C/ACs for their input. Given the proximity to the holidays,
>>>>> we propose giving groups until Friday, 31 January 2025 to provide their
>>>>> input to the Council.
>>>>>
>>>>>
>>>>>
>>>>> As noted during the Council’s previous discussions on the topic of
>>>>> accuracy, the Council recognizes the importance of accuracy and is
>>>>> committed to making progress on this issue. Your group’s responses to these
>>>>> questions are very important for the Council’s future discussion, and we
>>>>> strongly encourage your groups to think about these questions and provide
>>>>> candid responses.
>>>>>
>>>>>
>>>>>
>>>>> Thank you in advance for your input.
>>>>>
>>>>>
>>>>>
>>>>> Thanks,
>>>>>
>>>>> Greg
>>>>> _______________________________________________
>>>>> council mailing list -- council at icann.org
>>>>> To unsubscribe send an email to council-leave at icann.org
>>>>>
>>>>> _______________________________________________
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>>>>>
>>>>

-- 

*Poncelet O. Ileleji*

*Jokkolabs Banjul -  Lead / CEO*
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