Hello, Tucows is pleased to comment on the EPDP Phase 2 Priority 2 policy recommendations and thanks the EPDP team and ICANN support staff for their hard work through this process. Tucows supports these four recommendations, with the following clarifying comments: Regarding recommendation #20, redaction of the city field is an effective data protection activity in many circumstances; it is appropriate to allow the Registrar to determine whether data in that field should be redacted or disclosed. For Recommendation #21 we note that the retention obligation is specific to data required for the purposes of the Transfer Dispute Resolution Policy. Any implementation of this Recommendation must be similarly limited, to ensure that principles of data minimization and purpose limitation are respected. Thank you. -- Sarah Wyld, CIPP/E Policy & Privacy Manager Tucows swyld@tucows.com +1.416 535 0123 Ext. 1392