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 On Mon, Mar 10, 2025 at 12:15 PM Caitlin Tubergen < 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> *Reply-To: *Anne ICANN <anneicanngnso@gmail.com> *Date: *Monday, March 10, 2025 at 10:40 AM *To: *farzaneh badii <farzaneh.badii@gmail.com> *Cc: *GNSO Council List <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
Anne
Anne Aikman-Scalese
GNSO Councilor
NomCom Non-Voting 2022-2026
anneicanngnso@gmail.com
On Mon, Mar 10, 2025 at 9:46 AM farzaneh badii via council < 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.
2. *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.
3. *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...>
4. *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...>
5. *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.
7. *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...>
8. *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...>
9. *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...>
10. *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.
Farzaneh
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