System for Standardized Access/Disclosure: Difference between revisions
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The '''System for Standardized Access/Disclosure (SSAD)''' is a system proposed to centrally handle requests for non-public registration data, envisioned in Recommendations 1-18 of the Final Report of the GNSO Expedited Policy Development Process ([[EPDP]]) on the Temporary Specification for gTLD Registration Data Phase 2. | The '''System for Standardized Access/Disclosure (SSAD)''' is a system proposed to centrally handle requests for non-public registration data, envisioned in Recommendations 1-18 of the Final Report of the GNSO Expedited Policy Development Process ([[EPDP]]) on the Temporary Specification for gTLD Registration Data Phase 2. Whereas [[RDAP]] is an ''access'' protocol for registration data, [[SSAD]] is a ''request'' protocol. | ||
==History== | ==History== | ||
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==EPDP Phase 2 Final Report & Recommendations== | ==EPDP Phase 2 Final Report & Recommendations== | ||
Phase 2 of the [[Expedited Policy Development Process on the Temporary Specification for gTLD Registration Data (EPDP)|EPDP Temp Spec]] was largely focused on recommendation for | Phase 2 of the [[Expedited Policy Development Process on the Temporary Specification for gTLD Registration Data (EPDP)|EPDP Temp Spec]] was largely focused on the recommendation for the creation of a system of access and disclosure of anonymized or proxied registration data. Their final report was issued in July 2020.<ref name="finalrep">[https://gnso.icann.org/en/correspondence/epdp-phase-2-temp-spec-gtld-registration-data-2-31jul20-en.pdf EPDP Temp Spec Workspace - Phase 2 Final Report], July 31, 2020.</ref> The report's recommendations were intended to be an integrated set of proposals for a system where accredited parties could request nonpublic registration data from a centralized clearinghouse for such requests, and the determinations regarding such requests would be delegated to the relevant contracted parties.<ref>[https://www.icann.org/en/blogs/details/epdp-phase-2-team-publishes-final-report-10-8-2020-en ICANN.org Blog - EPDP Phase 2 Team Publishes Final Report], August 10, 2020</ref> The recommendations covered a variety of topics: | ||
* Accreditation of SSAD requestors, including governmental entities; | * Accreditation of SSAD requestors, including governmental entities; | ||
* Required criteria and content of SSAD requests; | * Required criteria and content of SSAD requests; | ||
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==Operational Design Phase== | ==Operational Design Phase== | ||
ICANN staff launched the [[Operational Design Phase]] (ODP) for the SSAD recommendations in April 2021.<ref name="odpdash">[https://www.icann.org/ssadodp ICANN.org - SSAD Operational Design Phase Dashboard], last updated January 25, 2022</ref> The ODP provided an opportunity to "assess the potential risks, anticipated costs, resource requirements, timelines, dependencies, interaction with the Global Public Interest Framework that is currently being piloted, and other matters related to implementation of the SSAD-related recommendations (1-18)."<ref name="odpdash" /> Because of the complexity of the system being proposed, the ICANN Board determined that it would be valuable for the organization to engage in that assessment.<ref>[https://www.icann.org/resources/board-material/resolutions-2021-03-25-en#2.c Resolution of the Board] initiating the SSAD ODP, March 25, 2021</ref> The Board drafted a scoping paper for the ODP, including questions for consideration.<ref>[https://www.icann.org/en/system/files/files/ssad-non-public-registration-data-odp-scoping-25mar21-en.pdf ICANN.org - SSAD Non-Public Registration Data ODP Scoping], March 25, 2021</ref> | ICANN staff launched the [[Operational Design Phase]] (ODP) for the SSAD recommendations in April 2021.<ref name="odpdash">[https://www.icann.org/ssadodp ICANN.org - SSAD Operational Design Phase Dashboard], last updated January 25, 2022</ref> The ODP provided an opportunity to "assess the potential risks, anticipated costs, resource requirements, timelines, dependencies, interaction with the Global Public Interest Framework that is currently being piloted, and other matters related to the implementation of the SSAD-related recommendations (1-18)."<ref name="odpdash" /> Because of the complexity of the system being proposed, the ICANN Board determined that it would be valuable for the organization to engage in that assessment.<ref>[https://www.icann.org/resources/board-material/resolutions-2021-03-25-en#2.c Resolution of the Board] initiating the SSAD ODP, March 25, 2021</ref> The Board drafted a scoping paper for the ODP, including questions for consideration.<ref>[https://www.icann.org/en/system/files/files/ssad-non-public-registration-data-odp-scoping-25mar21-en.pdf ICANN.org - SSAD Non-Public Registration Data ODP Scoping], March 25, 2021</ref> | ||
===Key Components=== | ===Key Components=== | ||
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===Operational Design Assessment=== | ===Operational Design Assessment=== | ||
ICANN org published its [[Operational Design Assessment]] on January 25, 2022.<ref name="odaannounce">[https://www.icann.org/en/announcements/details/icann-delivers-operational-design-assessment-of-ssad-recommendations-25-1-2022-en ICANN.org - ICANN Delivers ODA of SSAD Recommendations], January 25, 2022</ref> The Assessment identified a number of challenges with SSAD as proposed by the recommendations.<ref name="oda">[https://www.icann.org/en/system/files/files/ssad-oda-25jan22-en.pdf ICANN.org - SSAD Operational Design Assessment], January 25, 2022</ref> One of the largest issues was SSAD's interaction with proxy and privacy services offered by registrars. The assessment | ICANN org published its [[Operational Design Assessment]] on January 25, 2022.<ref name="odaannounce">[https://www.icann.org/en/announcements/details/icann-delivers-operational-design-assessment-of-ssad-recommendations-25-1-2022-en ICANN.org - ICANN Delivers ODA of SSAD Recommendations], January 25, 2022</ref> The Assessment identified a number of challenges with SSAD as proposed by the recommendations.<ref name="oda">[https://www.icann.org/en/system/files/files/ssad-oda-25jan22-en.pdf ICANN.org - SSAD Operational Design Assessment], January 25, 2022</ref> One of the largest issues was SSAD's interaction with proxy and privacy services offered by registrars. The assessment noted a study by [[Interisle]] from January 2021 that approximated that 86.5% of registered gTLDs were covered by either a proxy service or a privacy shield.<ref>[https://interisle.net/ContactStudy2021.pdf Interisle.net: WHOIS Contact Data Availability and Registrant Classification Study], January 2021, page 3 (PDF)</ref> As a result, the ODA noted, "the existence of proxy and privacy services poses several challenges to the system’s operations..."<ref name="oda" /> The SSAD as designed "assumes the system will only handle base-case requests for data for non-proxy/privacy service registrations,"<ref name="oda" /> and does not make any provision to compel production of registration data that is cloaked by a proxy or privacy service. Beyond the expectation that privacy or proxy services provide "full information" about the privacy or proxy service and the means of contacting such services, the [[Temporary Specification for gTLD Registration Data|Temporary Specification]] did not address such services. Because the EPDP charter addressed only the text of the Temporary Specification, the handling of proxied or private data was largely unaddressed.<ref name="oda" /> | ||
This finding gave rise to substantial concern among the ICANN Board. As [[Maarten Botterman]] noted in a letter to the GNSO Council, "[t]here is no guarantee that SSAD users would receive the registration data they request via this system" because such a high volume of registration data is contained within a proxy or privacy service.<ref name="odaletter">[https://mm.icann.org/pipermail/council/attachments/20220125/81d60ddc/2022-01-24BoardtoCouncilonSSADconsultation-0001.pdf GNSO Council Listserv Archive - Board to Council re: Upcoming SSAD Consultation], January 24, 2022</ref> Botterman's letter was intended to initiate conversation and thought prior to a scheduled meeting of the Board and GNSO Council on January 27, 2022.<ref name="odaletter" /><ref name="odpdash" /> That meeting was a constructive exchange of views on the viability of SSAD, although no conclusions were drawn. In particular, the discussants raised topics such as the merits and costs of accreditation, the legal risks involved in SSAD, the development of a requestor code of conduct, the need for a pilot version, shortening the timeline, and improving the estimate of potential users. | This finding gave rise to substantial concern among the ICANN Board. As [[Maarten Botterman]] noted in a letter to the GNSO Council, "[t]here is no guarantee that SSAD users would receive the registration data they request via this system" because such a high volume of registration data is contained within a proxy or privacy service.<ref name="odaletter">[https://mm.icann.org/pipermail/council/attachments/20220125/81d60ddc/2022-01-24BoardtoCouncilonSSADconsultation-0001.pdf GNSO Council Listserv Archive - Board to Council re: Upcoming SSAD Consultation], January 24, 2022</ref> Botterman's letter was intended to initiate conversation and thought prior to a scheduled meeting of the Board and GNSO Council on January 27, 2022.<ref name="odaletter" /><ref name="odpdash" /> That meeting was a constructive exchange of views on the viability of SSAD, although no conclusions were drawn. In particular, the discussants raised topics such as the merits and costs of accreditation, the legal risks involved in SSAD, the development of a requestor code of conduct, the need for a pilot version, shortening the timeline, and improving the estimate of potential users. | ||
==Simple Ticketing System== | == Whois Disclosure System (FKA Simple Ticketing System or SSAD Light)== | ||
The [[Whois Disclosure System]] was one outcome of the ODA was the development of an idea for a simple ticketing system (STS) designed to centralize requests for registrant information disclosures.<ref>[https://circleid.com/posts/20220404-icann-ssad-proposal-poised-to-succeed ICANN SSAD Proposal Poised to Succeed, Paul McGrady, CircleID]</ref> | |||
==References== | ==References== | ||