Hello everyone – I concur with Marc. And reiterate that because a registrar removes data from an RDS/WHOIS field (“Registrant Organization”) does not necessarily imply that they haven’t retained the data elsewhere in their non-public customers records. If the Council provides implementation guidance that explicitly requires Registrars to ensure that they have sufficient contact info for Registrant (and potentially, Registrant Org), then I agree this is the most practical approach. Thank you - J. ------------- James Bladel GoDaddy From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of "Anderson, Marc via Gnso-epdp-team" <gnso-epdp-team@icann.org> Reply-To: "Anderson, Marc" <mcanderson@verisign.com> Date: Thursday, October 31, 2019 at 9:00 AM To: "rafik.dammak@gmail.com" <rafik.dammak@gmail.com>, "gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] EPDP Phase 1 Consultation from GNSO Council regarding recommendation #12 Notice: This email is from an external sender. Rafik and EPDP team, Thank you for raising this. I’ve been following the GNSO council / ICANN board consultation on rec #12 closely. In the board’s 14 Oct response to council they clearly articulated their concern with Rec #12 using the ICANN.org domain registration as an example. To paraphrase they raised a scenario where the implementation of #12 could result in insufficient contact data associated with a domain registration. They go on to suggest a possible solution noting a similar scenario with the removal of the administrative contact and the specific language in Rec #29 addressing this potential issue. Rec #29 instructs Registrars to ensure Registered Name Holder contact info exists prior to deleting any admin contact data. As I understand Rafik’s email, the council is considering a path forward that adds implementation guidance (or similar) to Rec #12 instructing Registrars to ensure sufficient Registered Name Holder contact info exists prior to deleting any organization field data. Presumably this would then be passed to the ICANN policy team who would incorporate this guidance into the policy language for #12. This approach seems practical to me, and in line with the intent of Rec #12. Based on what Rafik has outlined in this email, I’m supportive of the approach council is considering. Best, Marc From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Rafik Dammak Sent: Wednesday, October 30, 2019 9:14 PM To: gnso-epdp-team@icann.org Subject: [EXTERNAL] [Gnso-epdp-team] EPDP Phase 1 Consultation from GNSO Council regarding recommendation #12 Dear EPDP Team, As the GNSO Council liaison to the EPDP Team, I wanted to provide you with an update on the status of consultations with the ICANN Board in relation to parts of the EPDP Phase 1 recommendations that were not adopted by the ICANN Board (recommendation #1, purpose 2 and recommendation #12 – deletion of org field data). Most recently: ● The GNSO Council wrote to the ICANN Board to share its take-aways from the engagement with the ICANN Board on this topic during ICANN65, to which a number of EPDP Team members contributed (see https://gnso.icann.org/en/correspondence/gnso-council-to-icann-board-09sep19...). ● The ICANN Board provided a response (seehttps://gnso.icann.org/en/correspondence/chalaby-to-drazek-14oct19-en.pdf<http://gnso.icann.org/en/correspondence/chalaby-to-drazek-14oct19-en.pdf>) which the Council discussed during its most recent meeting on Thursday 24 October 2019. As part of its consideration of the Board’s response, focusing on recommendation #12 –deletion of data, Council members tend to agree with the ICANN Board that everyone has the same goal in mind here “which is ensuring there are no inadvertent consequences of the deletion of data while ensuring compliance with applicable laws”. The Council, based on the input that has been provided by EPDP Team members, assumed that this notion was already implied in recommendation #12. However, noting the Board’s concern, the Council discussed during the 24 October meeting whether this could be made more explicit, for example in the form of implementation guidance, similar to how a safeguard was included in relation to the deletion of administrative data (“prior to eliminating Administrative Contact fields, all Registrars must ensure that each registration contains Registered Name Holder contact information”). Before further pursuing this approach (by way of an implementation guidance, instead of modifying recommendation #12), the Council would like to hear from the EPDP Team if there are any concerns about doing so or any other input the Council should consider as it aims to conclude the consultations with the ICANN Board. I realize that it is short notice, but if there are any initial reactions that I can take back to the GNSO Council before Sunday 3 November, this may already be informative as the Council will meet with the ICANN Board during ICANN66 and is expected to discuss this topic further during the Council meeting which is scheduled for 6 November 2019. I will also check with Janis to see if there are a couple of minutes we can carve out from the Saturday session to get some initial reactions. Looking forward to hearing from you. Best Regards, Rafik Dammak GNSO Council liaison to the EPDP Team