GNSO Council Accuracy Assignment - Questions to be answered by NCSG

Benjamin Akinmoyeje benakin at GMAIL.COM
Sat Feb 15 03:59:47 EET 2025 

Dear Farzi,
Thank you for attending to this request and sharing a well-thought-out
response.

As a community, it would be interesting if we could have this as a round
table discussion topic in the future.

Well done.

Kind regards,
Benjamin



On Sat, Feb 15, 2025 at 4:49 AM Poncelet Ileleji <pileleji at jokkolabs.co>
wrote:

> +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
>>>>>>
>>>>>> _______________________________________________
>>>>>> By submitting your personal data, you consent to the processing of
>>>>>> your personal data for purposes of subscribing to this mailing list
>>>>>> accordance with the ICANN Privacy Policy (
>>>>>> https://www.icann.org/privacy/policy) and the website Terms of
>>>>>> Service (https://www.icann.org/privacy/tos). You can visit the
>>>>>> Mailman link above to change your membership status or configuration,
>>>>>> including unsubscribing, setting digest-style delivery or disabling
>>>>>> delivery altogether (e.g., for a vacation), and so on.
>>>>>>
>>>>>
>
> --
>
> *Poncelet O. Ileleji*
>
> *Jokkolabs Banjul -  Lead / CEO*
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