[NCSG-PC] Comments on EPDP

[Ayden Férdeline]

Pam Little has repeatedly asked that "at a minimum" be removed from the language in the EPDP scope, and this was +1'd by Stephanie, but of course it was not actioned by staff... (the IPC's proposed language which received no cross-stakeholder group support was simply copied and pasted into the same document).

Ayden

‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
On 10 July 2018 7:31 AM, farzaneh badii <farzaneh.badii at gmail.com> wrote:

> Long time ago when I was 18, my friend had bought a car which was a big deal at the time and we were going from her parents' place to the university. My friend got distracted, wanting to show me a house in a street, she hit the traffic light and the traffic light broke collapsing over her car and just went blinking orange, green and red at our shocked faces. It was a bizarre feeling. Of course there was serious panic but also there was a very comical moment. The ePDP document with all the colorful comments and messiness gave me a very similar feeling.
>
> Now my main points:
>
> 1. We should not accept IPC addition to the mission. Also can we get rid of at a minimum from this paragraph? We are really working on "scope" and "mission" what does it mean at a minimum? is there a good reason it is there? If you don't remove it there is a risk that anything can be thrown at this document:
>
> "This EPDP Team is being chartered to determine, at a minimum, if the Temporary Specification for gTLD Registration Data should become an ICANN Consensus Policy. As part of this determination, the EPDP Team is, at a minimum, expected to consider the following elements of the Temporary Specification and answer the following charter questions:
>
> 2. Purposes for processing data. I am not so sure why Erika has added this question:
>
> a5) How shall legitimacy of collecting data be defined (at least for data from personal data collected from European users)? (proposed addition from Erika Mann)
>
> I thought legitimacy will be defined in accordance to purpose. Also the mention of "at least for data collected from European users" worries me.
>
> - Susan is suggesting to say should any purposes be "added". Sure, we could add that word but it has to be mentioned that according to ICANN purpose and mission, should any data be added.  EDPB specifically says that ICANN should not conflate its purpose with the interest of third party
>
> 3. I see that now even the phase 1, phase 2 has been removed and access has become a part of EPDP. Can we get rid of accreditation and just discuss access at this EPDP? I see that Susan Kawaguchi supports this ...
>
> 4. Overall we need to have the EDPB recent guidelines into account. On data retention issue for example for example, the EDPB explicitly says ICANN has to justify why each element of data has to be retained for two years. So the question on data retention is not about whether ICANN should adjust data retention requirements but that if it is justifiable for ICANN to require data retention of 2 years and on which elements.
>
> 5. section J. Please reject all IPC additions.
>
> 6.Lets talk about access and not accreditation if we are not winning to remove access from EPDP. Seems like Susan agrees.
>
> Farzaneh
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