[NCSG-PC] GNSO Council Accuracy Assignment - Questions to be answered by NCSG
farzaneh badii
farzaneh.badii at gmail.com
Fri Feb 14 23:07:43 EET 2025
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
>>>>
>>>> _______________________________________________
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>>>>
>>>
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