Dear Colleagues,

Following up on our discussion yesterday, I checked with the Legal team about a couple of items that were discussed.

With respect to the proposed edits to the PPAA that are related to data processing (see, e.g. Section 3.5.3 of the contract and the new draft Specification 8), provisions on these topics must be included in this contract, though these can be edited based on your feedback.

If you have suggested edits to these new provisions, please send them to the list and we can discuss them on the call next week. If, as discussed yesterday, you believe the inclusion of these provisions raises more fundamental questions about status, in light of the pending ePDP on similar topics, we can also discuss that.

As a reminder, the way the PPAA is drafted, any new ICANN Policy that is in conflict with current provisions (GDPR-related or otherwise) would supersede any conflicting provisions in this contract.

On the overall timeline, and additional deliverables, any additional GDPR-related changes will be based on IRT feedback. We have a couple of additional discussion topics that we didn’t reach last week, which could require additional PPAA changes. We’ll discuss these next week:
1. Are the disclosure frameworks intended to give Providers limited or no discretion on disclosure if other requirements in the framework are met?
2. What should requirements be for a Provider’s logging of disclosure requests from third parties?

We are continuing to review the contract for any copy-editing related issues, and I expect we will finish with those in the next week or so.

I hope this is helpful. Please continue to consider these issues and share any feedback you have on-list. We can pick up on these issues next week.

Thanks, and have a great weekend!

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