Re: [council] Letter regarding Harassment / Conduct at ICANN Meetings

[David Cake <dave@xxxxxxxxxxxx>]

I’ve suggested this source previously elsewhere - its a very useful resource. 
While the creating organisation, the Ada Initiative, has shut down, I know some 
people involved and would be happy to get in touch with them for further advice 
if it would be useful. 

Regards

David

> On 18 Apr 2016, at 1:57 PM, Jennifer Gore Standiford <JStandiford@xxxxxxx> 
> wrote:
> 
> Hello All,
>  
> Not to further jump on the bandwagon, just to restate the main objective of 
> this working group was to create a document that addresses ‘Harassment at 
> ICANN Conference/Events’.  In my opinion, if we expand the scope to include 
> religion, political viewpoints, etc. we will need to go back to the drawing 
> board.  Reg Levy provided a great online source for reference on the 
> Registrar Stakeholder Distribution list today:
>  
> https://adainitiative.org/continue-our-work/conference-policies/ 
> <https://adainitiative.org/continue-our-work/conference-policies/>
>  
> Unfortunately, the source is geared towards women, however I believe it would 
> be relevant to refer to it within the attached document if and when we decide 
> to send it to ICANN.  
>  
> The source includes key items such as:
>  
> ·         Example of a Conference Anti-Harassment Policy
> ·         List of Conferences that have a Policy
> ·         Why such a Policy is needed
>  
> I realize we have received constructive input in the last 2-3 days and it was 
> my conclusion that the council agreed to move forward on a submission by 
> close of business today, Monday 4.18.16. So I am a little unsure as to how we 
> should proceed?  
>  
> ICANN Staff, James, Councilors – thoughts on this matter?
>  
> Thank you,
> Jennifer
>  
>  
>  
>  
>  
> From: owner-council@xxxxxxxxxxxxxx [mailto:owner-council@xxxxxxxxxxxxxx] On 
> Behalf Of Phil Corwin
> Sent: Monday, April 18, 2016 12:24 PM
> To: Volker Greimann; egmorris1@xxxxxxxxx; James M. Bladel; GNSO Council List; 
> Stephanie Perrin
> Subject: RE: [council] Letter regarding Harassment / Conduct at ICANN Meetings
>  
> Volker:
>  
> Respectfully, your comment makes me even more uneasy about the path we seem 
> to be proceeding down.
>  
> This dialogue began with a general consensus that some form of sexual 
> harassment policy was needed for ICANN meetings. Then it expanded to cover 
> other forms of verbal behavior that someone might find offensive , 
> objectionable, or harassing.
>  
> Now you suggest that a policy should cover not just statements denigrating an 
> individual’s religious preference but an affirmative statement of religious 
> belief. I would agree that proselyting for any spiritual outlook or belief 
> system is not germane to a WG’s responsibilities, but the GNSO WG rules 
> already provide the Chair(s) with authority to take action against disruptive 
> or irrelevant postings.
>  
> What next will be added to the list of potential offenses? Political 
> statements? – try discussing the current US Presidential election without 
> offending someone. Not even the weather is a safe subject, given the 
> polarization of views over global warning.
>  
> I would hope that we can keep any list of possible verbal offenses (I am 
> excluding physical acts from these comments, as they are a whole other 
> matter) that can give rise to initiation of an investigative/adjudicatory 
> procedure to those that are really intentional and serious, and not one-off 
> or boneheaded statements for which a simple admonition and apology might 
> resolve the matter. We need to preserve ICANN as an open forum for expression 
> of views.
>  
> Best to all,
> Philip
>  
> Philip S. Corwin, Founding Principal
> Virtualaw LLC
> 1155 F Street, NW
> Suite 1050
> Washington, DC 20004
> 202-559-8597/Direct
> 202-559-8750/Fax
> 202-255-6172/Cell
>  
> Twitter: @VlawDC
>  
> "Luck is the residue of design" -- Branch Rickey
>  
> From: owner-council@xxxxxxxxxxxxxx <mailto:owner-council@xxxxxxxxxxxxxx> 
> [mailto:owner-council@xxxxxxxxxxxxxx <mailto:owner-council@xxxxxxxxxxxxxx>] 
> On Behalf Of Volker Greimann
> Sent: Monday, April 18, 2016 9:27 AM
> To: egmorris1@xxxxxxxxx <mailto:egmorris1@xxxxxxxxx>; James M. Bladel; GNSO 
> Council List; Stephanie Perrin
> Subject: Re: [council] Letter regarding Harassment / Conduct at ICANN Meetings
>  
> Hi all,
> 
> a recent mail on a PDP WG reminded me that we should work on a more general 
> policy. While the current plans would take care of one "flavor" of 
> inappropriate behavior, there are many more that would not be addressed by a 
> policy focussed only on sexual harrassment. For example religious 
> proselytizing has no room within ICANN either.
> 
> Best,
> 
> Volker 
> 
> 
> 
> 
> Am 18.04.2016 um 14:57 schrieb Edward Morris:
>  
>  
> James, all,
>  
> I am in receipt of Stephanie's comments on the proposed harassment letter. I 
> encourage the Council to consider many of  these suggested changes to be the 
> equivalent of hostile amendments to the work produced by our small Council 
> working group and to reject most of them,  both on procedural and substantive 
> grounds, The document produced by the small Council working group led by 
> Jennifer is far superior to one incorporating changes proposed at the last 
> minute by Stephanie and should be used as our references note going forward. 
>  
>  
> PROCEDURAL PROBLEMS
>  
>  
> A note about how we have worked on this matter as a Council. At the Marrakech 
> meeting I raised the issue of sexual harassment. A small working group was 
> formed consisting of four Councillors from the NCSG - myself, Stefania, 
> Marilia, David - and one Councillor from the Registrars in Jennifer. All 
> Councillors were invited to join this group. Mary Wong kickstarted the group 
> into action with an e-mail of March 25th. Jennifer immediately took the lead 
> and on March 28th produced the prototype of the document now before us. I 
> immediately suggested a few minor changes to the document, which were 
> accepted. There were 17 email exchanges amongst the members of the small 
> working group and staff prior to release of the final document to the general 
> Councll list. 
>  
> Once on the Council  list suggestions and comments  made on a timely basis by 
> Donna and Phil, were acknowledged by Jennifer, and incorporated into the 
> document. Stephanie responded on April 6th with some general comments that I 
> believe could are best summarised by this part of her post:
>  
> "It is my view that we need a privacy policy more than a harassment policy 
> because I feel that inappropriate conduct is already in fact covered by by 
> our acceptable conduct policy"
>  
> This represents a completely different view than that adopted by the small 
> working group. I personally reject both the premise and the conclusion. 
> Harassment is a specific type of conduct that has connotations beyond the 
> term "inappropriate". It is not adequately covered by current policy. I 
> should note that although Stephanie's  comments have been on list for twelve 
> days, no one other Councillor has posted agreement with Stephanie's view that 
> ICANN should deal with the situation at hand through it's acceptable conduct 
> policy.
>  
> As Stephanie's suggestions were a bit different in format than the other 
> comments and not as easy to adapt to the document at hand on April  6th 
> Jennifer asked Stephanie to produce a red line version of her comments. On 
> April 7th Stephanie agreed. This project had a completion deadline of April 
> 14th. No other Councillor objected to the small group proposal on list 
> between the 7th and 14th. Then on our monthly call  Stephanie verbally 
> objected to our draft, the time frame was  extended and we waited through the 
> weekend for her input. Finally, eleven days after she agreed to produce a red 
> line document, four days after the initial project deadline, Stephanie has 
> responded. Thank you for your input, Stephanie.
>  
> If this material had been produced in a timely manner it could have 
> stimulated discussion on the list, it could have stimulated discussion on our 
> call. Instead, I view this as no more than a  way of almost  hijacking the 
> process, I'm sure without any malicious intent - Stephanie has impeccable 
> integrity,  at the very end so in the end  the positions she espouses are 
> adopted out of necessity rather than as a result of considered debate. I'm 
> somewhat resentful that I now have to spend a few hours of my Monday 
> responding to wholesale suggestions of change that were promised weeks 
> earlier. If the Council is to allow this type of behaviour  then why would 
> any of us join small working groups? Why not just wait until the end, past 
> the deadline, of all projects and then object to things when you have the 
> most leverage? I don't believe this is an optimal way to conduct our 
> business, whatever the reason.
>  
> I also take exception to Stephanies claim that "I attach a markup version of 
> both documents.  I have circulated them to the NCSG". As far and I can tell, 
> that simply is not true. I have not seen these documents prior to this post 
> to the Council list. I've checked both the NCSG discussion list and the 
> archives of the NCSG policy committee list and no such "circulation" seems to 
> have occurred. Those are our only two official mailing lists in the NCSG. I 
> also note that the majority of NCSG Councillors were on the small team that 
> Jennifer so aptly led. The NCSG had ample opportunity as a group to object to 
> the proposed reference note in a timely manner and chose not to do so.
>  
>  
> SUBSTANTIVE PROBLEMS
>  
> 1. Stephanie has created at the outset a list of questions. Some of these 
> have suggested outcomes that we did consider early in the small group and 
> rejected, others would have been appropriate to consider at that time. 
> Stephanie chose not to join this group and to challenge our decisions only at 
> this late date.
>  
> -
> While events at ICANN55 focused on the need for a Conference Harassment 
> Policy, would it not be prudent to create a Harassment Policy that covers all 
> of ICANN’s activities?
> ?
> No.
>  
> Let's be clear: ICANN already has a variety of harassment policies. There is 
> a harassment policy, required by California law, that covers employees. There 
> is the Expected Standards of Behaviour which may or may not cover some forms 
> of harassment. That policy was found to be flawed in the most recent highly 
> publicised situation. I should note that both parties in that matter support 
> the development of a conference sexual harassment policy.
>  
> ICANN is an outlier in not having a conference harassment policy. The 
> International Association of Conference Centres recommends as standard 
> industry practice that a "conference specific, clearly defined policy against 
> harassment  be posted at prominent entry points". I see no reason for ICANN 
> to reject standard industry practice in this regard.
>  
> Meetings introduce the concept of "clear and present danger" into the 
> equation. The standards for behaviour of those in close physical proximity to 
> one another may necessarily need to be  bit more stringent than that of a 
> more general policy.
>  
> Harassment itself is also different than general conduct standards in that 
> for harassment to occur it must be directed towards a specific individual. 
> There is also a mens rea component of harassment not present in most of the 
> items contained in the Expected Standards.
>  
> ICANN is best served by a conference specific harassment policy with clearly 
> defined roles and responsibilities. 
>  
> That said, I certainly would have no objection if a phrase akin to "we hope 
> that the development of  a conference harassment policy is only the first 
> step towards developing a wider policy against harassment in all of ICANN's 
> activities and affairs" were added to the letter if that would meet with 
> Stephanie's approval.
>  
>  
> 2.    If not, how does one deal with harassment that continues after an 
> event, or starts online or through conference calls, meetings, etc. outside 
> the actual face to face conferences?
>  
>  
>  
> Through normal processes. This is not an either / or situation. Some, 
> including myself, believe that the lack of a conference specific policy is a 
> hole in an otherwise satisfactory policy requiring civil behaviour. I should 
> also note that ICANN is not a state. There are also opportunities to deal 
> with these matters through normal channels. However, given that ICANN does 
> hold meetings in countries where harassment may be permitted legally, a 
> specific conference harassment policy does provide some de facto  assurance 
> of some protection within the meeting site. It is a challenge. See, for 
> example: 
> http://www.dailymail.co.uk/news/article-3534495/US-woman-jailed-insulting-United-Arab-Emirates.html
>  
> <http://www.dailymail.co.uk/news/article-3534495/US-woman-jailed-insulting-United-Arab-Emirates.html>
>  as to what we are facing going forward.
>  
>  
> 3. What is the purpose of a harassment policy, and how does it intersect with 
> the existing standards of behavior policy?  
> (https://meetings.icann.org/sites/default/files/icann-standards_of_behavior-jul14.pdf
>  
> <https://meetings.icann.org/sites/default/files/icann-standards_of_behavior-jul14.pdf>
>  
> The purpose of a conference harassment policy is to create policy which 
> produces an environment in which all attendees are comfortable in and is one 
> which attendees are free from harassment of any kind. It does so by 
> delineating specific conduct that is prohibited and by establishing clear 
> reporting obligations and requirements. This is far greater than the current 
> ESB requirement that everyone act civilly towards one another.
>  
> I would also opine that the current policy does not work when applied to this 
> type of incident   and the lack of a conference policy of a specific nature 
> exposes ICANN legally.
>  
>  
> 4. How does one differentiate between inappropriate remarks or actions, and 
> harassing, demeaning, and abusive behavior?  Many harassment policies scope 
> the offensive activity or actions in terms of repeated behavior that forms a 
> pattern, or if only a single event, an event that is of very significant 
> proportions (eg physical contact).  A policy must be clear enough that when 
> Implementation guidance and training is provided, our global multicultural 
> audience will be able to understand clearly when conduct and speech are 
> unwelcome or inappropriate, and when they are very offensive to normal 
> sensibilities and constitute harassment.  Defining normal will be challenging.
>  
>  
> These question largely go to implementation and are beyond the scope of our 
> current, initial, policy reference point.
>  
>  
> Regarding Stephanies criticisms of specific points contained in the "ICANN 
> Conference Harassment Policy - Key Points" distributed by James on 15 April 
> at 22:55 UTC:
>  
> 1. I support the text as written without any changes, although certainly 
> believe it could be approved. Please remember this is a mere reference point.
>  
> 2. As harassment by definition is directed at an individual I reject 
> Stephanies concerns for the section beginning "inappropriate communication".
>  
> 3. As Stephanie rightly notes ICANN as a private corporation has no control 
> over whether an accused party seeks legal redress for any perceived harm. The 
> prohibition against retaliation is a necessary clause that encourages victims 
> to come forward but as with all policies written by a private corporation the 
> effect of said policy is limited to the corporations remit. That is true of 
> this entire document. I woulds not want to limit the language as operation of 
> law already constrains it's reach and I would prefer that the 
> anti-retaliatory language be as broad as legally possible. The current 
> language meets that goal. I should note the same concerns have been expressed 
> concerning whistleblower policies and have been  found to be lacking.
>  
> 4. I reject Stephanie's assertion that you need to "train a couple of 
> thousand conference attendees to recognise and prohibit this type of 
> conduct". That is FUD. This policy empowers those who witness such behaviour 
> to report it given that often the power relationship involved makes it 
> impossible for the victim to report it. I note this is mere reporting; no 
> judgement as to validity of the complaint is being made.
>  
> Although I would prefer to keep the language as is, I would have no objection 
> to changing "should immediately" to "are encouraged to immediately" if that 
> would address some of Stephanie's concerns.
>  
> 5. I not only reject Stephanie's assumption that the Ombudsman is or should 
> be the first line for reporting, our small group, at my request, deleted this 
> concept from our proposal. First, the Ombudsman in not empowered by the ICANN 
> Bylasws to conduct investigations into relations between parties that have no 
> direct contractual relationship with ICANN. That he did in the most recent 
> publicised incident is being considered for litigation (against ICANN) by one 
> of the parties involved and has prompted me to write a letter to Steve 
> Crocker asking for an explanation / justification (response yet to be 
> received). There are people within ICANN corporate in the human relations 
> department who have expertise in this area and who I believe are far better 
> qualified to handle these types of complaints than the Ombudsman. That said, 
> I would prefer for ICANN corporate, not us,  to establish the reporting 
> structure in line with other responsibilities and expertise of their 
> employees. 
>  
> 6. The line "ICANN will protect the confidentiality of individual(s) 
> reporting suspected violations of the incident(s) to the extent permissible 
> and with due regard for procedural fairness" is good language and should be 
> retained. Stephanie's proposed substitution is too limiting ('investigations 
> and interviews conducted under this policy"), too defined ("confidential") 
> and would expose ICANN to greater legal liability should a party be 
> dissatisfied. The text in the proposed document is read as a "best effort" 
> clause and would not expose ICANN legally except in the case of gross 
> negligence. 
>  
> 7. I agree with the clause requiring staff members who become aware of "any 
> form of harassment or potential incidents": to report them to the front line 
> employee given responsibility for these matters. This is not just good policy 
> in terms of stopping harassment, this is good policy in terms of limiting 
> ICANN's exposure to lawsuits resulting from such incidents.
>  
> I do not believe putting links to nonspecific government harassment policies 
> has any value whatsoever. ICANN is not a government, it is a private 
> corporation. We are not trying to create, in this action, a comprehensive 
> harassment policy, but rather a conference harassment policy. Links to 
> specific conference harassment policies, of course, would be most welcome if 
> anyone wants to spend the time to find and link to them. 
>  
> As stated, I would prefer to keep the letter and reference document as 
> written. I respectfully disagree with Stephanie on many of her comments and 
> by timing her response so late there really isn't time to engage in a full 
> conversation as would be desirable. 
>  
> However, if it is deemed permissible for Stephanie's last minute changes to 
> the proposed document to be accepted over my objection then I respectfully 
> request the following additional changes be made:
>  
> - Addition of an opening clause
>  
> ?This policy aims to strengthen and safeguard the ICANN working environment 
> so that it is a welcoming and enabling diverse environment for stakeholders 
> from all backgrounds.
>  
> - Change the word 'colour' to 'ethnicity'
>  
> - Exclude the word 'disability', as that term is now considered to be 
> somewhat derogatory'; handicap should suffice
>  
> - change 'sex' in all instances to 'gender'; 'sex' has connotations that does 
> not fully describe the wide array of possible sexual identification 
> categories that 'gender' does;
>  
> -, include 'stalking' as a prohibited offense
>  
>  
> Again, my preference would be to go with the document as is. I will remind 
> everyone that this is merely a reference note to provide an example of what a 
> policy might look like. There will be ample opportunity for the community to 
> weigh in on the actual proposed policy at a later date.
>  
> I note also that Phil has made some additional recommendations today to  
> strengthen the proposal. My principle objection is timing (although in a 
> different procedural environment I would consider them friendly amendments)  
> - I am generally in agreement , at least in part, with all but one of his 
> proposed changes. I will note that Phil's earlier recommendations have been 
> incorporated into the document. His current proposals and my responses:
>  
> 1. What procedural due process protections will be established for parties to 
> the dispute, and what standard of proof shall be required for an adverse 
> finding.
>  
> I agree that this would be a useful addition to the accompanying letter as a 
> bullet point.
>  
> 2. I believe we need a standard that requires some intent on the part of the 
> alleged harasser to demean, denigrate, harass, etc.
>  
> Harassment by legal definition has a mens rea component. I would not object 
> to making this clear in the policy document but do not believe it is 
> necessary.
>  
> 3. policy needs to be further developed to make clear that conduct of a 
> criminal nature (assault, indecent exposure, rape) is outside the scope of 
> any harassment policy and is to be reported by ICANN to the proper 
> authorities.
>  
> We need to be careful here. It may not be clear whether an activity is or is 
> not illegal. I would not want to create any legal obligation for ICANN to 
> report any alleged crime. I'd suggest that rather than put this in out policy 
> proposal we add another bullet point to the letter akin to:
>  
> - We believe procedures need to be developed so that those matters that are  
> violations of law are reported immediately by ICANN or the complaining party 
> to the proper authorities.
>  
> I think we need to note this but I would be hesitant in a rushed manner to 
> come up with exact wording within the proposed "key points". I'm fine with a 
> bullet point in the letter.
>  
> - “You should report any actions that you believe may violate this policy no 
> matter how slight the actions might seem” I would suggest deleting everything 
> after the word “policy”, leaving more discretion to a target or witness to 
> decide when to invoke whatever procedures may be created to deal with 
> harassment.
>  
> I agree.
>  
> 
> -Finally, I would suggest that the term “ICANN Conference” needs to be 
> clearly defined to make clear its breadth. That is, does it only cover 
> incidents that occur  at the official meeting site or are other locations and 
> activities covered; such as meeting sponsor social events, official meeting 
> hotels, etc.?
>  
> Good point. I would limit the policy to the meeting itself, I don't believe 
> ICANN should limit the free expression rights of sponsoring organisation, but 
> am open to other ideas.
> 
>   
> WAY FORWARD
>  
>  
> The GNSO is late in making this submission. We do need to act now.
>  
> My preference would to have had this conversation during the past few weeks 
> these documents have been posted and open for participation. 
>  
> I have no objection to changes in the documents to which there is no on list 
> opposition. I have, however, objected to several of the changes proposed for 
> substantive policy reasons. These documents have been available and open for 
> comment for about two weeks. The deadline for this project was supposed to be 
> last Thursday. Unless more widespread opposition is voiced, I would suggest 
> the document as presented in James weekend e-mail be considered approved and 
> sent. That said, I have no objection to requested changes by Stephanie and 
> Phil that have not met with any opposition by EOB today to be incorporated in 
> the final document. Where challenged, however, I believe we should stick with 
> the original language in the absence of more widespread opposition.
>  
> I want to thank all my my colleagues for their work on this and, in 
> particular, Jennifer, whose leadership and hard work have made this happen. I 
> have very much enjoyed working with her.
>  
> Respectfully,
>  
> Ed 
>  
>  
>  
> From: "Stephanie Perrin" <stephanie.perrin@xxxxxxxxxxxxxxxx> 
> <mailto:stephanie.perrin@xxxxxxxxxxxxxxxx>
> Sent: Monday, April 18, 2016 4:10 AM
> To: "James M. Bladel" <jbladel@xxxxxxxxxxx> <mailto:jbladel@xxxxxxxxxxx>, 
> "GNSO Council List" <council@xxxxxxxxxxxxxx> <mailto:council@xxxxxxxxxxxxxx>
> Subject: Re: [council] Letter regarding Harassment / Conduct at ICANN Meetings
>  
> Thanks for circulating this James.  I agree with Phil's recent comments, but 
> I attach a markup version of both documents.  I have circulated them to the 
> NCSG, but I think it is fair to say there are divergent views on this topic, 
> so these are my own personal comments.  As I have expressed, I think we are 
> rushing into a complex area here and I do hope that once Akram comes up with 
> a draft, there will be ample opportunity to discuss and refine the document.
> Kind regards
> Stephanie Perrin
>   
> On 2016-04-15 16:18, James M. Bladel wrote:
> Council Colleagues -
>  
> As discussed during yesterday’s call, we intend to send a high-level letter 
> to ICANN (Akram) on behalf of the GNSO Council, thanking him for his blog 
> post and drawing his attention to statement from the NCUC and the draft 
> policy created by Jennifer and others.  (On this latter point, I’ve edited 
> the Key Points document to reflect the most recent comments on the thread).
>  
> If you have any comments or edits to the letter or “Key Points” document, 
> please post these to the list by EOD Monday, 18 APR.  Edits could include 
> changes/additions to the language, as well as inclusion of other materials or 
> links to statements from other groups.
>  
> The target is to post this letter by Tuesday, 19 APR.
>  
> Thanks—
>  
> J.
>  
> 
>  
> 
> 
> 
> -- 
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> Mit freundlichen Grüßen,
>  
> Volker A. Greimann
> - Rechtsabteilung -
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