SENT ON BEHALF OF DENNIS CHANG Dear Anne and Councilors, ICANN org informed the IRT on 8 August 2024 that billing contact data must still be collected and retained pursuant to current RAA requirements. In response, some members of the IRT expressed the view that the absence of a reference to billing contact data was a drafting error, and the EPDP Team intended for the collection of billing contact data to be optional and not mandatory. On 25 September 2024, there was a special meeting of the IRT<https://community.icann.org/display/RDPIRT/2024-09-25+Registration+Data+Poli...> to discuss the topic of billing contact data. No objection to the position of a drafting error was raised during the special meeting, nor were objections raised on the list following the meeting. ICANN org understands the position expressed by the IRT members is that the absence of a recommendation on billing contact data was a drafting error, and the EPDP Team intended to make registrar collection and retention of billing contact data optional. Following the dedicated IRT meeting and having heard no objection to the IRT’s position of drafting error, ICANN org requested further guidance from the GNSO Council because, as the Council has discussed, there is no policy recommendation regarding the billing contact. I hope that is helpful context. Please let me know if you have further questions. I also invite Thomas, the GNSO Council liaison to the IRT and a member of the EPDP Team to provide additional context if needed. -- Kind Regards, Dennis S. Chang GDD Programs Director Phone: +1 213 293 7889 Signal: dc21.21 www.icann.org<http://www.icann.org> One World – One Internet From: Anne ICANN <anneicanngnso@gmail.com> Date: Sunday, March 23, 2025 at 4:00 PM To: Caitlin Tubergen <caitlin.tubergen@icann.org> Cc: farzaneh badii <farzaneh.badii@gmail.com>, GNSO Council List <council@gnso.icann.org> Subject: Re: [Ext] Re: [council] Re: Preliminary research on EPDP discussion on billing contact Gee Caitlin - the language you have identified from the IRT deliberations doesn't appear to support the concept of a "drafting error". I pasted some language below. Can we please get a note from Dennis Chang of ICANN confirming the IRT determination that billing contact should be removed? Many thanks for tracking this down. Anne Note from Dennis as per link: "You will note that some have asked about the inclusion of Billing Contact fields in the Registrar Data Escrow Specification. We cannot remove it as a requirement for the following reasons: Current requirements pertaining to data escrow are specified in Section 3.6 of the RAA. Under these requirements, registrars must escrow the data described in Subsections 3.4.1.2 through 3.4.1.5, which includes but is not limited to the Billing Contact data. Further, the Registration Data Policy includes requirements related to processing “Registration Data” as defined by the policy under Section 6. The Registration Data Policy will not modify or replace existing requirements under the RAA that are not specifically addressed and modified by the policy recommendations, including those requirements related to the processing of the Billing Contact data." Anne Aikman-Scalese GNSO Councilor NomCom Non-Voting 2022-2026 anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com> On Thu, Mar 20, 2025 at 11:20 AM Caitlin Tubergen <caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org>> wrote: Hi Anne, Please find links to some of the IRT discussions on billing contact: 1. https://lists.icann.org/hyperkitty/list/irt.regdatapolicy@icann.org/thread/S... [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/irt.regda...>. 2. https://lists.icann.org/hyperkitty/list/irt.regdatapolicy@icann.org/thread/U... [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/irt.regda...> Kind regards, Caitlin From: Anne ICANN <anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com>> Date: Thursday, March 20, 2025 at 12:58 PM To: Caitlin Tubergen <caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org>> Cc: farzaneh badii <farzaneh.badii@gmail.com<mailto:farzaneh.badii@gmail.com>>, GNSO Council List <council@gnso.icann.org<mailto:council@gnso.icann.org>> Subject: [Ext] Re: [council] Re: Preliminary research on EPDP discussion on billing contact HI Caitlin - many thanks for this info. Could you please forward the email showing the IRT's determination with respect to the billing contact drafting error? Based on Thomas' explanation, I think it may be preferable for Council to refer to this as an underlying assumption of the outcome of the deliberations rather than a "drafting error". Thank you, Anne Anne Aikman-Scalese GNSO Councilor NomCom Non-Voting 2022-2026 anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com> On Mon, Mar 10, 2025 at 12:15 PM Caitlin Tubergen <caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org>> wrote: Hi Anne, Yes, you are correct – the billing contact discussion is directly linked to the Registration Data Policy<https://www.icann.org/resources/pages/registration-data-policy-2024-02-21-en...>. The Registration Data Policy<https://www.icann.org/resources/pages/registration-data-policy-2024-02-21-en...> was published in February 2024 and goes into effect on 21 August 2025. Following the publication of the Registration Data Policy, as Contracted Parties began updating their systems, a question arose about billing contact (specifically the collection and transfer of billing contact info to the registrar data escrow agent). I hope that answers your question, but please let me know if you have any additional questions. Kind regards, Caitlin From: Anne ICANN via council <council@icann.org<mailto:council@icann.org>> Reply-To: Anne ICANN <anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com>> Date: Monday, March 10, 2025 at 10:40 AM To: farzaneh badii <farzaneh.badii@gmail.com<mailto:farzaneh.badii@gmail.com>> Cc: GNSO Council List <council@gnso.icann.org<mailto:council@gnso.icann.org>> Subject: [council] Re: Preliminary research on EPDP discussion on billing contact Thank you, Farzi. Question for staff: Is this policy for Registration Data relevant to the Billing Inquiry? Item 4 in the document says the policy becomes effective August 21 of 2025. tps://www.icann.org/resources/pages/registration-data-policy-2024-02-21-en#policy-effective-date<http://www.icann.org/resources/pages/registration-data-policy-2024-02-21-en#...> Anne Anne Aikman-Scalese GNSO Councilor NomCom Non-Voting 2022-2026 anneicanngnso@gmail.com<mailto:anneicanngnso@gmail.com> On Mon, Mar 10, 2025 at 9:46 AM farzaneh badii via council <council@icann.org<mailto:council@icann.org>> wrote: Hi all, Hope you are enjoying the opening ceremony. As promised I did some research on how and where billing contact was mentioned and discussed and so far have found the following: Preliminary Research Background on Billing Contact at EPDP: 1. August 2018 – Initial Mentions of Billing Contact: * Billing contact was first mentioned during EPDP calls. * Registrars discussed the utility of Admin/Tech contacts and their overlap with billing contacts. * A message from this period: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> mentions the duplicity of contact roles (admin, tech, billing) and questions the necessity of collecting and sharing redundant information. 1. November 2018 – EPDP Team Meeting #26: * A discussion on excluding billing contact, particularly in the context of ICANN’s involvement: * A message from this meeting: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...>, which includes discussions on billing being related to a processing activity between contracted parties and their customers, with no involvement of ICANN. 1. January 2019 – Discussion on Deletion of RDS Elements: * ICANN org sought input on deleting Administrative and Billing Contact information (note: billing contact data is not published). * Relevant email: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> * Another email in 2019 from ICANN org asking the group to address billing contact: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> 1. Allan Woods’ Position (2019): * Allan Woods argued against including billing contact in the EPDP discussions: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> 1. Kristina Rosette (2019) – Discussion on Billing Contact and Registration Data: 6. * Kristina Rosette argues that billing data should not be considered as part of registration data due to its vague connection with the domain registration process: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> * She also mentions a proposed revision of the definition of “Registration Data” to exclude such data. 1. Sarah Wylde (2019) – Support for Allan Woods’ Argument: * Sarah Wylde supports Allan Woods’ position and argues that billing is not a data collection purpose for ICANN: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> 1. Trang’s Query on Recommendation 11 and RAA: * Trang raised a question on whether the current text of Recommendation 11 would replace RAA Section 3.4 regarding billing contact: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> 1. Allan Greenberg response: * Allan Greenberg did not dispute the elimination of billing contact: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> 1. Small Team B Discussion in 2019: * Billing contact was briefly discussed by Small Team B, noting that it is not considered within the scope of processing data for ICANN purposes: Link [lists.icann.org]<https://urldefense.com/v3/__https:/lists.icann.org/hyperkitty/list/gnso-epdp...> I hope this helps. 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