Fully Concur Farzaneh, It's a brilliant idea and others similar should also be turned to a blog, Kudos Ephraim for putting this together. Thank you *Poncelet O. Ileleji* *Jokkolabs Banjul - Lead / CEO* *Sait Matty Road, Bakau, Adjacent to Swedish Consulate* *KMC, The Gambia* *P O Box 4496 Bakau,KMC, The Gambia* *Skype: pons_utd* *Tel Direct Office: +220 4495115* *Tel Mobile/Whatsapp: +220 9912508* *LinkedIn: Jokkolabs Banjul* *Facebook: Jokkolabs Banjul* *Twitter: @jBanjul* On Mon, Dec 18, 2023 at 5:40 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 >>> >>