Dear EPDP team, 

 

In reviewing the CPH proposal in response to the first action item listed below, ICANN org would like to share with you the following implementation-related considerations regarding the “Disclosure Request Process” steps listed in the proposal. Some questions may apply more broadly to all the models under consideration by the EPDP, while others are specific to the CPH proposal. 

 

  1. Step #4 indicates that the “ request is routed to the applicable contracted party.” Who is the applicable contracted party: the registry or the registrar or is it both? (This question also applies to the other models under consideration by the team.)
  2. #5: Would the request be automatically pushed to the Contracted Party via a system, or is the Contracted Party responsible for logging into a system to review requests? If so, how often? Monthly? Daily? Etc. Would this time frame include weekends and holidays? In addition, 5.A references two (2) business days. Whose business days does this reference? The Contracted Party? The requestor?  The portal? 
  3. #6A notes that the Contracted Party will “provide the data to the requestor  (most likely directly in order to avoid ICANN unnecessarily processing personal data).”  How will the data get to the requestor? Would the requestor pull it from the contracted party or would the contracted party push it to the requestor?  Would they use RDAP? Email? Web interface? 
  4. #6 B&C: Will the disclosure decision solely be up to the discretion of the Contracted Parties? Does ICANN have an enforcement role with regard to disclosure decisions? (This question also applies to the other models under consideration by the team.) For example what should ICANN do if:
    1. A Contracted Party accepts every single request?
    2. A Contracted Party rejects every single request?

 

Thank you,

 

Eleeza and Dan

ICANN org liaisons

 

 

 

From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of Caitlin Tubergen <caitlin.tubergen@icann.org>
Date: Friday, January 17, 2020 at 6:45 AM
To: "gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org>
Subject: [Gnso-epdp-team] EPDP Action Items

 

Dear EPDP Team:

 

Please find below a friendly reminder of outstanding EPDP Team action items:

 

1.                  EPDP Team to share ideas / thoughts / proposals in response to the CPH proposal and Mark Sv. slides, both of which are attached herein, by COB Friday, 17 January. Following receipt of proposals, EPDP Support Staff to develop new proposal factoring in the input received and the small team discussions by Tuesday, 21 January.

2.                  EPDP Team to provide detailed concerns or proposed edits to the questions proposed by the Legal Committee, attached herein, by COB Friday, 17 January.

3.                  IPC/BC and ISPCP colleagues to update the Initial Report Google doc to include previously-submitted feedback by Monday, 20 January.

4.                  Brian to propose a footnote clarifying cost causation under Financial Sustainability section by Monday, 20 January.

5.                  Amr, Brian, Stephanie & Franck to clarify intent of statement “under no circumstances should registered name holders be expected…” under Financial Sustainability section by Monday, 20 January.

6.                  When applying changes to the draft Initial Report Google Doc, EPDP Support Staff to add comments, noting the date and rationale why the text was changed, e.g., EPDP Team agreed to change may to must during Meeting #xx.

 

Thank you.

 

Best regards,

 

Marika, Berry, and Caitlin