Thanks
Romina

El lun, 18 dic 2023 a las 15:24, Peter Micek (<[log in to unmask]>)
escribió:

> 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
>>>>>
>>>>