On Sat, 24 Oct 2009, William Drake wrote:

> Hi Ron,
>
> Normally we (and other civil society coalitions I know of that are involved 
> in global policy debates & negotiations) don't go through elaborate processes 
> like voting in order to offer simple endorsements of partner coalitions' 
> statements, particularly when they go in the same direction as our own 
> efforts, and this would be particularly difficult with something time 
> sensitive.  Certainly I've never seen it done, in any event.
>
> Do you have a substantive concern with the document, or are you only raising 
> a process point?
>
> Thanks,
>
> Bill

hi Bill,

concerned about NCUC setting a good example on reaching conclusions.
as has been discussed before, some of us individual members may be
members of organizations that we would like to represent, but we have
to show these organizations that their membership (and thus implied
endorsement of the actions of NCUC) would be carefully represented.

is the proposed endorsement for an active member of NCUC or how in this
case is the group defined as a partner coalition?


what i am suggesting is that when we have time, that a person suggesting
the NCUC endorse something, that they post a section on the NCUC web
site saying how the target group is associated/partnered/admired, a 
member, etc. by NCUC with a brief summary of the document (with a link
to the full text) and why it makes sense for NCUC to endorse it.   a
note to the list would be good as well, but then we'd have a central
place to discuss the proposal.  this works toward our goal of increasing
participation from "bottom up".

when we do endorse something, then it would be good to have a section
on the public NCUC web pages that includes the endorsements that the 
NCUC has signed.

the mailing list request for signing in the absence of any objections 
is at least transparent.

###

the declaration itself is broad, and the author has collected a very
wide-reaching set of concerns.   but in many ways, it is merely an
enumeration of hot-topic issues with no substantial goals for adressing
them.  an example of this is (3) which only offers stronger adjectives
such as "genuine" and "meaningful" without meaningly commenting on
shorcoming of current practice.

i'm troubled by (2) because it appears to set up "independent data 
protection authorities" that will have absolute powers for 
"determinations".  the call for independence from political influence 
does not assure any structure that would be distinguishable from 
how ICANN has functioned.

the declaration seems focused on Europe, with specific ratification
goals and since NCUC certainly includes Europe, it may be appropriate
to support these goals, but from my point of view this is "political"
as it requires governments to approve these specific measures.

i do feel that (6) is well written and has my full support.

some governments, such as California USA, have required notifications
called for in (7).  i have some concern that in the wrong hands, the
disclosure that information has been compromised, if individuals are
named, can itself harm privacy.

(9) seems unworkable and if it were implemented and enforced would be
intrusive into both individual and academic research.

and finally (10) is hard to support since rather than work to enlarge
the scope of existing privacy protections, calls for a "new international
framework" which worries me as it would be a delay and distraction from
achieveing the goals enumerated.

since this is very time-sensitive, then i'm not suggesting that we delay,
just bringing forth items for discussion rather than blanket endorsement.

-ron