[NCSG-PC] latest letter, the response to the March 8 GDPR compliance model

[Nick Shorey]

Hi everyone,

At present I cannot support submission of the previous draft, so please see
attached updated document with comments and edits.

Key points:

- The document should be restructured to put the summary recommendations at
the start;
- Need to be clearer in our assessment of whether this proposed solution
should be implemented (or not);
- Where possible, keep our responses based upon facts;
- I'm really uncomfortable with some of the paragraphs (2,3,5) in the
Tiered Access Models section. Just sounds like a rant;
- Be clearer in our views on GAC oversight of accreditation, bypassing of
MLAT and our recommendation for cross-community expert group.

Kind regards,

Nick

*Nick Shorey*
Phone: +44 (0) 7552 455 988
Email: lists at nickshorey.com
Skype: nick.shorey
Twitter: @nickshorey
LinkedIn: www.linkedin.com/in/nicklinkedin
Web: www.nickshorey.com

On Sun, Mar 11, 2018 at 3:18 PM, Stephanie Perrin <
stephanie.perrin at mail.utoronto.ca> wrote:

> Yet if  you did either the PIA or the HRIA you would get this outcome
> Milton....I am reluctant to lose it.  Possibly just pull it back into a
> more neutral statement.
>
> cheers SP
> On 2018-03-11 11:08, Mueller, Milton L wrote:
>
> Another thing I forgot to mention. I was boarding a flight. I think the
> paragraph about abiding by all data protection laws in the world should
> also be struck. Of course we agree with that in some sense but on the other
> hand it’s overkill. Trying to get them to except a little of privacy they
> already don’t want, I don’t think it makes a lot of sense to demand the
> entire world of them in that statement
>
> Milton L Mueller
> Professor, School of Public Policy
> Georgia Institute of Technology
>
> On Mar 11, 2018, at 09:14, Stephanie Perrin <stephanie.perrin at mail.
> utoronto.ca> wrote:
>
> I am really happy to delete that paragraph Milton, you have put your
> finger on the risk.  I will change it to a strong statement on model three
> being the only choice compliant with law until a professional, MS
> accreditation system (that contains audit and oversight) has been developed.
>
> Cheers Stephanie
> On 2018-03-11 05:46, Mueller, Milton L wrote:
>
> On the whole it is a very strong letter. I have one very strong objection
> and would ask you to delete this paragraph:
>
>
>
> A small group of expert community members that can work with the GAC
> might be a better way to come up with a tiered access system before the
> law comes into effect.
>
>
>
> This is asking for trouble. Anything that happens in the next two months
> is going to be sloppy and biased toward what GAC wants. As Farzy suggested
> we should insist on them adopting model 3 until tiering methods and
> criteria are worked out.
>
> Milton L Mueller
> Professor, School of Public Policy
> Georgia Institute of Technology
>
> On Mar 10, 2018, at 18:02, Stephanie Perrin <stephanie.perrin at mail.
> utoronto.ca> wrote:
>
> Ok folks, here is the letter as currently drafted.   COmments welcome.
> Thanks to Ayden for many useful comments
>
> Stephanie
>
> <March 8 ICANN gdpr modelncsg4.docx>
>
>
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