[NCSG-PC] Fwd: Late markup

[Stephanie Perrin]

I think it is likely they will accept none of my comments....too late.  But I will hold my ground.

Thanks for reading it.  Obviously my principal objection is that it was framed entirely the wrong way in the first place.  Plus an unnecessary review at this time.  But that ship sailed during the first meeting in Brussels, which I attended remotely (never a good option when you are the minority) because I had to go to the DPAs meeting around the same time to finish the ICANN report.

Too much work, too few hands on deck.  However, the good news is we now have 9 members who are intimately familiar with the WHOIS fight, fresh from the EPDP, so we have more folks who can hit the many pdps that will have to resolve some of the issues mentioned under Anything New.....

Cheers Stephanie

On 2019-03-04 02:32, Ayden Férdeline wrote:
Thanks for this Stephanie, I have just reviewed your annotated version of the report and your analysis is excellent. You are more diplomatic than I would have been though! Please do stand your ground; I hope they do not just publish the final report ignoring your comments and instead seek to address them... but is there any possibility that they will do that?

Ayden


‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
On Monday, March 4, 2019 7:00 AM, Stephanie Perrin <stephanie.perrin at mail.utoronto.ca><mailto:stephanie.perrin at mail.utoronto.ca> wrote:


I sent the attached markup of the final RDS REview II to the review team.  I do not like the tone of the report, nor do I really support many of the recommendations, particularly the sections on Law Enforcement and accuracy.  One could tear apart the way the survey was done, the bias against privacy, etc.  I was alone on these issues, with occasional support from Volker.  I think he just gave up as this being shortly to be proven irrelevant.

Anyway, here it is, for those with boring plane rides where they want to fall asleep.  I did not verify the correct transpostion of the appendices, nor the definitions.

Cheers Steph


-------- Forwarded Message --------
Subject:
        Late markup

Date:
        Mon, 4 Mar 2019 00:51:46 -0500

From:
        Stephanie Perrin <stephanie.perrin at mail.utoronto.ca><mailto:stephanie.perrin at mail.utoronto.ca>

To:
        RDS WHOIS2-RT List <rds-whois2-rt at icann.org><mailto:rds-whois2-rt at icann.org>




Attached is my markup of the document.  Overall, this document is impressive in its scope and research.  Basically, I think many of our recommendations are sensible.  However, the bias towards disclosure of information, the negative attitude towards the GDPR (which my SG applauds as exemplary effort to protect privacy and human rights), and the absence of any explicit recognition of the fact that our WHOIS practices already violated data protection law during the time of the past review are discouraging.  Not to mention the fact that the birth of ICANN coincided with the coming into force of the EU directive, and we have had plenty of advice from the DPAs over the past 19 years telling us how to fix it.   The push to continue doing what we have done since ICANN was born, regardless of changing risks, improvements in data protection, and the existence of many other ways to achieve the security and stability of the Internet, is discouraging.  I realize we had to review the recommendations of the previous Review team.  We live in different times, however, and the evidence of that impacting our review is not there.

Given how many issues I have reservations about, I would like to make a statement, but I am not quite sure where it belongs.  I do not want to resist consensus, but I do want to register some frustration with this process and final result.  I do appreciate that I am a minority view and that you have tolerated my raising my comments and objections throughout the process.

Stephanie Perrin

Chair, NCSG


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