Agreed, this is a great exercise. I like the idea of using this simple template to evaluate more policies and statements. Thanks, Peter On Mon, Dec 18, 2023, 1:10 PM Benjamin Akinmoyeje <[log in to unmask]> wrote: > Dear Farzaneh, > Great idea, I hope you will consider the NCUC website as a great place to > publish the blog. > > This is an important topic that many of our members are passionate about. > > Kind regards, > Benjamin > > On Mon, Dec 18, 2023 at 7:40 PM farzaneh badii <[log in to unmask]> > wrote: > >> Thank you Ephraim. >> >> I am going to turn this into a blog. If the policy committee and NCSG >> decides to turn it into a letter getting broader feedback from the >> membership and send it to the board that would be great. >> >> Policy Committee can you please have a look at this? >> >> Farzaneh >> >> >> On Sun, Dec 17, 2023 at 11:17 AM Ephraim Percy Kenyanito < >> [log in to unmask]> wrote: >> >>> Awesome stuff Farzaneh! >>> >>> >>> -- >>> >>> Best Regards, >>> Ephraim Percy Kenyanito >>> Public Policy Specialist/ Regulatory Affairs Specialist/ Project Manager- >>> International Trade, Technology, Media & Telecommunications Laws >>> Website: https://ekenyanito.com/ >>> Twitter: @ekenyanito <https://twitter.com/ekenyanito> >>> PGP Fingerprint: B0FA394AF73DEB7AA1FDC7360CFED26DE6BA8DC1 >>> >>> >>> On Sun, 17 Dec 2023 at 02:46, farzaneh badii <[log in to unmask]> >>> wrote: >>> >>>> Hi NCSG >>>> >>>> I have started doing HRIA on GAC Communiques. I started with a >>>> Communique in Cancun. >>>> >>>> If NCSG and NCSG Policy Committee wants to, they can send this (with >>>> amendments and comments) as a letter to the Board. I am hopefully going to >>>> periodically do that and the next one is the GAC communique on urgent >>>> requests. Link to document to comment on: >>>> https://docs.google.com/document/d/1kmXgKaob7lIULB_6dXIepeZ7l2e6AzAJcfzAhuBKSEg/edit?usp=sharing >>>> >>>> The text: >>>> >>>> Governments asking for confidentiality of law enforcement requests for >>>> access to domain name registrants personal, private data: A human rights >>>> impact assessment >>>> >>>> WHOIS Disclosure System >>>> >>>> a. The GAC advises the Board: >>>> >>>> i. To direct ICANN org to promptly engage with the PSWG to identify and >>>> advance >>>> >>>> solutions for confidentiality of law enforcement requests so as not to >>>> preclude >>>> >>>> participation by law enforcement requesters when measuring usage of the >>>> WHOIS >>>> >>>> Disclosure System. >>>> >>>> Governmental Advisory Committee/ Cancun, Mexico, 2023 >>>> <https://www.icann.org/en/system/files/correspondence/gac-to-icann-20mar23-en.pdf> >>>> >>>> Sources used: Business Social Responsibility Rapid Human Rights >>>> Assessment: >>>> https://www.bsr.org/files/BSR-Rapid-HRDD-Political-Armed-Conflict-Tool.pdf >>>> >>>> Rapid human rights impact assessment: >>>> >>>> The situation: WHOIS is the directory that includes the domain name >>>> registrants private, personal, sensitive data such as phone numbers, >>>> physical addresses and email addresses. Domain name owners can set up >>>> websites around the world. This database was public and accessible for >>>> years until General Data Protection Regulation came into effect which >>>> required redaction of data. However, GDPR also had provisions for >>>> disclosing the private data to third parties with a legitimate purpose. >>>> GDPR is vague on how such disclosure can take place. >>>> >>>> >>>> Rightsholders: Rightsholders in this situation are domain name >>>> registrants. >>>> >>>> Impacted vulnerable communities: potential impacted communities can be >>>> minority groups that discuss sensitive issues on their blog that are >>>> unfairly illegal in their countries. Such as minority religious groups, >>>> minority political oppositions and others. >>>> >>>> What is the severity of the actual or potential human rights impact? >>>> >>>> Unfair arrest, potential imprisonment, illegal house raids, cruel >>>> punishments >>>> >>>> What are the potential long-term implications of the situation? >>>> >>>> Decrease in use of domain names and public websites for exercising >>>> fundamental rights >>>> >>>> Inaccuracy of the database >>>> >>>> Peer companies that are taking action that the company can consult with >>>> directly? >>>> >>>> Regional Internet Registries that have similar WHOIS databases do not >>>> make the requests confidential, they report on which countries asked for >>>> the data in their transparency reports (See RIPE NCC) >>>> https://www.ripe.net/publications/lea-documents >>>> >>>> What can ICANN do to avoid, prevent, or mitigate the actual or >>>> potential human rights impacts? >>>> >>>> ICANN should not grant law enforcement agencies the option to seek >>>> disclosure of data confidentially from the registrars. >>>> >>>> >>>> >>>> Farzaneh >>>> >>>