Dear Colleagues, Following up on our discussions at ICANN63, I want to provide some additional context around next steps for the Privacy/Proxy IRT. As noted during several discussions in Barcelona, ICANN org believes that there is currently a significant amount of uncertainty around interpreting the data processing requirements of GDPR related to this type of proposed accreditation agreement. Until we gain enough certainty to address this, we don't believe it's prudent to move forward at our prior pace. Areas of uncertainty include, but are not limited to: * The purposes of gTLD registration data, including contact data that is protected by a privacy or proxy service; * The lawful bases for processing of gTLD registration data, including: * Collection; * Retention; * Transfer of data to third parties, including data escrow agents and third-party requestors; * Allocation of controller/processor obligations w/r/t gTLD registration data; and * The expected solution for third-party access to non-public registration data (and whether this might be applied to PP customer data, which would impact implementation of the PP accreditation program). Many of these issues will be considered in the Expedited PDP on the Temporary Specification for gTLD Registration Data and continued ICANN org discussions with the European Data Protection Board. As a result, we believe we should continue to monitor this work as we proceed to finalize other, unrelated aspects of the proposed program requirements. IRT Action Items During meetings in Barcelona, many IRT members had questions about the IRT's status. If you have additional questions or comments about next steps, please send them to the list. In addition, if you have suggestions for items that you believe should be discussed now, please also send those to the list. I'll continue to update you via the list on work being done on this project by ICANN org. We plan to schedule meetings periodically (every 4-6 weeks) to ensure that you have the opportunity to raise questions or issues you would like to discuss with the group. During these meetings, we can also discuss progress made in other parallel efforts, and potential impacts that these efforts may have on proposed PP accreditation requirements. Regards, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>