Dear Accuracy Scoping Team colleagues, Per the group's request from a couple of weeks ago, please find below some comments/response from ICANN Org/Compliance to the Gap Analysis Proposal D re potential Registrar Audit(s). ICANN Org and Compliance colleagues would be happy to answer further questions the group might have after reviewing and discussing further. Best, Brian Comments from ICANN Org / ICANN Contractual Compliance: ICANN Contractual Compliance (Compliance) may proceed with registrar audit(s) that confirm compliance with Registration Data accuracy obligations within the Registrar Accreditation Agreement (RAA) and Whois Accuracy Program Specification of the RAA, including validation and verification processes, without review of nonpublic personal data in registration data. This is consistent with Compliance’s last full registrar audit. Compliance may consider taking additional steps to audit compliance with accuracy requirements, such as obtaining and reviewing records that contain personal data in registration data and specifically demonstrate verification and validation of redacted registration data. However, prior to taking any further steps in this area that would involve the processing of redacted registration data collected by registrars, ICANN org believes it should solicit guidance from the European data protection authorities prior to taking any further steps in this area, as discussed with the community at ICANN73. Once the criteria for the registrar audit is established, Compliance is typically able to initiate an audit within 2 months. Compliance would first need to establish the content of the audit itself, selection criteria, and process (e.g. single audit, batches, continuous, etc.). If registration data must be obtained through sources other than public Registration Data Director Services (RDDS), for e.g. the contracted party, data escrow provider(s), etc. this may impact the timing of initiating or completing an audit. From: GNSO-Accuracy-ST <gnso-accuracy-st-bounces@icann.org> on behalf of Marika Konings <marika.konings@icann.org> Date: Tuesday, April 19, 2022 at 12:20 AM To: "gnso-accuracy-st@icann.org" <gnso-accuracy-st@icann.org> Subject: [GNSO-Accuracy-ST] Thursday's meeting to continue development of details of proposals with those interested Dear All, Similar to last week’s meeting, coming Thursday’s meeting will be dedicated to working on the details of the different proposals as outlined here (https://docs.google.com/document/d/1sScP8MwgDCg4yvFNAYwQVql7DQob60vX/edit?pl... [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/1sScP8MwgDCg4y...>). Special thanks to Sarah for providing initial responses that the group reviewed and discussed during last week’s meeting. The staff support team has accepted these responses and added in suggestion mode some additional points and questions that were raised during last week’s discussion (see page 12 & 13). If there is anything we missed, or any further input you would like to see considered, please add this to the document in advance of Thursday’s meeting. For Thursday’s meeting, we’ll start off with proposal E and then circle back to proposal A, and possibly D if a response is received from ICANN org in relation to the questions that the group posed concerning a possible Registrar Audit. Best regards, Caitlin, Berry and Marika