Greetings, Colleagues.
Thank you for all of your input on the draft Privacy and Proxy Service Provider Accreditation Agreement (“PPAA”).
Attached, you will find an updated PPAA, which incorporates the comments received. I am also working on updating the issues list and will be distributing the list some time tomorrow.
For tomorrow’s call, we can begin by discussing some of the high-level issues some of the IRT members have raised. Specifically:
Additionally, I’d like to note two things. First, further to Darcy’s message today, the GNSO Council recently voted to move the Transfer Policy (IRTP-C) issue for discussion within the PPSAI IRT. I believe the Council directed this issue to be discussed during the public comment period. Darcy, please feel free to add additional context either on the list or on tomorrow’s call.
Lastly, there have been several mentions of GDPR as a potential issue/barrier to the PPSAI implementation. I would like to note that ICANN has engaged legal experts to analyze the impact the European Union General Data Protection Regulation (“GDPR”) will have on various data processing activities under ICANN policies and contracts. Such policies and contracts require or permit various entities that participate in the gTLD domain name system, including registries and registrars, to collect, create, retain, escrow, and publish a variety of personal data elements related to registry/registrar operations, domain name registrations, and registrants.
The legal review and analysis is being conducted in iterative phases, and ICANN gathered questions from community discussions and submissions to submit to the legal experts for possible discussion in Part 2 of the analysis. One of the questions included the following: “ICANN org is working with the community to develop implementation details for consensus policy recommendations governing the accreditation of privacy and proxy providers. How should GDPR requirements be factored into developing the accreditation process?” We will certainly keep you apprised of any feedback we receive.
See you on our call tomorrow.
Kind regards,
Caitlin