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Dear Padmini,
Thank you for sharing this document with the discussion group.
I write with full disclosure that I have not been a part of the Documentary Information Disclosure Policy (DIDP) subgroup and have not been involved with your work to date. However, moving forward, I hope I will be able to contribute to your research and the drafting of your recommendations.
This document is a great starting point but I'd like to suggest we add some more evidence, adopt a more neutral tone in some of the sentences, and strengthen the recommendations.
I was wondering how the examples of best practices you cite in this document were chosen? Given how many data protection bodies there are globally, why did you decide to cite Finland’s Act on the Openness of Government Activities on page two, for instance? I suspect it is very liberal and I understand the desire to borrow best practices from a faster-moving body. However, the cynic in me thinks I could identify hundreds of similar bodies with worse or identical practices to what ICANN has on the release of information in its possession, custody, or control. It is perfectly reasonable to turn to Finland; I just think the argument would be more persuasive if we could explain why this example is relevant. You do this when citing India’s Right to Information Act — that table which compares and contrasts how ICANN works in relation to the Indian government is brilliant and its arguments compelling.
Some of the language is also a little emotive. I know we in the NCSG are probably on the same page on this topic, but phrases like “it cannot be denied” are just asking for trouble if we send this through to those on the CCWG-Accountability given the myriad of members present. (And please correct me if I'm wrong here, as I don't have a lot of background as to DIDP subgroup or who it reports to - this is being sent to the CCWG-Accountability, right? Or is it going somewhere else? I have a feeling I might be a bit lost here as to the intended audience.)
Finally, the conclusion is just too short. It's one sentence and all we're asking is that the CCWG-Accountability “acknowledge … these challenges and suggestions so that transparency can be truly, meaningfully achieve[d]”. I worry about this recommendation. It's easy for those receiving this document to say, 'okay, acknowledged', and to take no further action. Can we instead come up with 5 or 6 tangible actions we would like taken instead?
Thanks again to everyone who was involved in drafting this document. It's looking great and with a few small revisions I think we will have something very persuasive and loaded with evidence. If I can help in any way with research or in drafting the actionable recommendations, I'm happy to do so. And if I have mistaken the audience for this document or its intention (and I do worry that I have!), I apologise for wasting your time, but please understand I am fascinated by the topic and just not too informed as to how this subgroup was established or of its history.
Best wishes,
Ayden
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