Yuko, Thank you for sharing the proposed data dictionary/data model. I will be in-flight during our 24-Apr small team call, so wanted to share these thoughts via email before the call. Since Cancun, the BC has been pressing ICANN staff to share their data model for the Registrant Data Request System (RDRS). We asked for the data model in order to understand whether RDRS would capture and retain enough detail to help us analyze the nature and origin of requests, evidence provided, reason given, etc. Also whether the requests result in disclosures, and why disclosure was denied. We are glad to see that the proposed (attached) data model does include the detail we sought. However, Yuko’s email below indicates ICANN will not make the detail available to community members for analysis. That’s different from when the BC agreed to proceed with SSAD Light. At that time, the staff design paper<https://www.icann.org/en/system/files/files/whois-disclosure-system-design-p...> and addendum<https://gnso.icann.org/sites/default/files/policy/2022/correspondence/ducos-...> indicated access to data, even for non-participating registrars: "The system will provide reporting on a periodic basis not to exceed the recommended durations. The exact form of the reporting is to be determined. It is envisioned that eventually the data will be made available through the Open Data platform for public consumption." (p.31) Staff added this to the addendum<https://gnso.icann.org/sites/default/files/policy/2022/correspondence/ducos-...> at p.4: “To facilitate the evaluation of the WHOIS Disclosure System, the small team will continue to work with ICANN Org to ensure that the necessary data is available to ensure the proper evaluation of the Whois Disclosure System, taking into account legal limitations that may exist to share certain information.” As the BC representative on this Council small team<https://community.icann.org/pages/viewpage.action?pageId=186779415>, I am asked to continue pressing the need for someone ( ICANN staff or trusted experts ) to be prepared to perform detailed analysis of the data before drawing any conclusions about whether to proceed with a full-blown SSAD. From: GNSO-EPDPP2-SmallTeam <gnso-epdpp2-smallteam-bounces@icann.org> on behalf of Yuko Yokoyama <yuko.yokoyama@icann.org> Date: Wednesday, April 19, 2023 at 2:59 PM To: gnso-epdpp2-smallteam@icann.org <gnso-epdpp2-smallteam@icann.org> Subject: [GNSO-EPDPP2-SmallTeam] RDRS Data Dictionary Dear Small Team members, Please see attached ICANN org’s data dictionary for the Registration Data Request Service. This document provides all the data fields captured in the system from both requestor and registrar sides, in a more digestible manner than the ones in the Design Paper<https://www.icann.org/en/system/files/files/whois-disclosure-system-design-p...>. * Tab 1: All the data fields captured in the requestor side of the System * Tab 2: All the data fields captured in the registrar side of the System * Tab 3: Reporting criteria specified in the Addendum<https://gnso.icann.org/sites/default/files/policy/2022/correspondence/ducos-...> and whether those are reportable Please note, this document is being shared for the purpose of transparency and to showcase that the reporting criteria that are specified in the Addendum can be achieved with the data elements being collected. Additionally, our aim is that this document can aid in the Small Team’s discussion should it wish to add additional reporting criteria. We would like to add that ICANN org will not share any raw data collected through the System with external parties outside the System. While we understand the importance of transparency and accountability, we also want to ensure that ICANN org respects the privacy and the confidentiality of the requests logged through the system. The monthly reports will provide the necessary metrics as detailed in the Addendum, along with any other metrics deemed necessary by the Small Team to the extent that the data is available in a systematic manner, with the metrics being based on numerical and usage data. It should be noted that certain data elements listed in the data dictionary, for example, names of requestors, evidence and attachments, will not be analyzed or used as metrics for any other purpose that would go beyond gathering usage data. ICANN org ensured that the principles of privacy-by-design are embedded in the System’s design and development from its inception. Principles such as role-based data access limitation, data minimization, and data retention, were carefully considered and the publication of raw data would violate these principles. It is also important to remember that the purpose of this proof-of-concept system is not to perform contextual or content analysis, for example, evaluating the legitimacy of registrars’ disclosure decisions or analyzing outcome trends. We want to emphasize that GNSO Council's request and the ICANN Board's direction is to implement a cost-effective system that will simplify the process for submitting and receiving requests for nonpublic gTLD registration data for both the requestors and registrars and to report on usage of this system to help inform the Council–Board consultations on the next steps for the SSAD recommendations. Regards, Yuko Yokoyama Program Director Strategic Initiatives, Global Domains & Strategy Internet Corporation for Assigned Names and Numbers (ICANN) Direct Line: +1 310 578 8693 Mobile: +1 310 745 1517 E-mail: yuko.yokoyama@icann.org<mailto:yuko.yokoyama@icann.org> www.icann.org<http://www.icann.org/>