[NCSG-PC] [NCSG EPDP] draft comments on the EPDP final report

Tomslin Samme-Nlar mesumbeslin at gmail.com
Tue Mar 30 12:33:02 EEST 2021


Thank you again everyone for the comments, edits and discussion. It is
20:00 on 30th April now my time. So I have to either submit it before I go
to bed or first thing in the morning. However, if there are no more
comments to the draft, I'll prefer submitting it before I go to bed.

Cheers,
Tomslin


On Tue., 30 Mar. 2021, 10:46 Stephanie E Perrin, <
stephanie at digitaldiscretion.ca> wrote:

> Ok I have added bits as requested....I did not accept your rejection of
> the premise that the accreditation body cost estimate may be low.  This
> is not based on my opinions alone, it is is based on all the work done
> in private by the EWG....we looked at the possible options for
> accreditation of entities, and it was considered by all to be a
> nightmare and potentially expensive.  I also worked on this, including
> with respect to cross border data sharing in my capacity of DG Risk
> Management when I was at Service Canada....managing credentials for
> users of a global system is extremely expensive.  I used the term "may"
> so we are not making a fact assertion, but I will be stunned if they can
> do this for that kind of budget. Remember that permitting the wrong
> users eg criminals into the system would be the cause of a major data
> breach, which comes with big $$$ penalties.  If there are no further
> comments I will go in , accept your additions, and turn it over to
> Tomslin to submit.  (what day is it for you Tomslin?  ) we have approx
> 24 hours to the deadline.
>
> cheers and thanks for the comments Milton!  I don't necessarily agree
> with totally downpedalling the cost issues but am willing to compromise
> on it, we have signalled strongly that this is a new payer and you left
> that in.
>
> Steph
>
> On 2021-03-29 2:25 p.m., Mueller, Milton L wrote:
> > Stephanie:
> > Really appreciate the work involved in the first draft.
> > I am commenting on the doc and I want to alert everyone in NCSG that I
> think it is a major strategic error for our comments to reinforce the
> IPC/BC's attacks on the financial viability of the SSAD. The SSAD is viable
> if the users (e.g., Facebook, Markmonitor, etc) pay for it. When the
> surveillance caucus says it is too costly they are just angling for free
> access and our having registrars and registrants pay for it. When you
> reinforce the false argument that this will be too expensive, you are
> advancing their agenda. Not deliberately, of course, but you seem to be
> unaware of how your argument shoots us in the foot.
> >
> > During the negotiations over the SSAD, NCSG's position was that users
> pay for their own accreditation costs, and that usage of the system should
> be tiered to differentiate between light and heavy users. Also, the
> existence of an SSAD helps us argue for keeping the private data redacted.
> >
> > So I have suggested various changes and deletions in the comments to
> reflect this perspective.
> >
> > --MM
> >
> >
> > -----Original Message-----
> > From: EPDP <epdp-bounces at lists.ncsg.is> On Behalf Of Stephanie E Perrin
> > Sent: Thursday, March 25, 2021 4:20 PM
> > To: NCSG PC <ncsg-pc at lists.ncsg.is>; 'epdp (epdp at lists.ncsg.is)' <
> epdp at lists.ncsg.is>; kathy at dnrc.tech
> > Subject: [NCSG EPDP] draft comments on the EPDP final report
> >
> > Here is the link to the draft comment
> >
> https://nam12.safelinks.protection.outlook.com/?url=https%3A%2F%2Fdocs.google.com%2Fdocument%2Fd%2F1AEQv0knS3fI_AaCNWAr3Y4H1sf1BlUgani4dqcBQZ48%2Fedit%3Fusp%3Dsharing&data=04%7C01%7Cmilton%40gatech.edu%7Ca6ce1b2a2bbf4f35e41f08d8efcb5633%7C482198bbae7b4b258b7a6d7f32faa083%7C0%7C0%7C637523004364133736%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=a4Ynu4ypaEqf%2BlpL6BQykzPkInixeCFof%2BKQVapNces%3D&reserved=0
> >
> > Please let me know if you have trouble editing
> >
> > cheers Stephanie Perrin
> >
> > _______________________________________________
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> > EPDP at lists.ncsg.is
> >
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