Hello Team, Thank you Kurt & staff for providing this updated recommendation text. The RrSG continues to support keeping it optional for the Registrar to decide if they want to collect the Tech contact info. If the Registrar does not collect the Tech field, those fields should be left blank in the RDS output (no other contact set should be substituted into these fields). This is in line with GDPR Art. 25 principle of Privacy by Design and by Default. -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 1/25/2019 7:20 PM, Kurt Pritz wrote:
Hello Everyone:
As we turn toward the weekend, please review at your convenience the latest addition to the email list discussion.
Following deliberations in this week’s plenary meeting, please find below the proposed updates to recommendation #4 having to do with the data elements collected and also our policy discussions regarding the Tech Contact data. The leadership & support teams hope this accurately reflects the current state of deliberations. Also note that the discussion during the meeting this week also resulted in some updates that have been applied to other Recommendations (e.g., Compliance) for how to refer to the data elements workbooks.
We’ve included the wording of our policy conclusions but you will note that we did not include the data table itself as that table is be reconsidered by the Data Elements Team.
In its discussions, the EPDP Team sought to eliminate reliance upon the data elements workbooks as authoritative and the wording has been adjusted (as it has in other recommendations) to accommodate that.
*Recommendation #4 - Initial Report Version*
The EPDP Team recommends that the data elements defined in the data elements workbooks in Annex D are required to be collected by registrars. In the aggregate, this means that the following data elements are to be collected (or automatically generated): Refer to bottom of document for data elements.
*Recommendation #4 - Updated version*
The EPDP Team recommends that the data elements listed below (as illustrated in the data elements analysis in Annex D) are required to be collected by registrars. In the aggregate, this means that the following data elements are to be collected, where some data elements are automatically generated and, as indicated below, in some cases it is optional for the registered name holder to provide those data elements:
[[[Include data elements table, including optional and automatically generated fields]]]
For further details, see complete data elements matrix.
For the purpose of the Technical contact, which is optional for the Registered Name Holder to complete (and if the Registrar provides this option), Registrars are to advise the Registered Name Holder at the time of registration that the Registered Name Holder is free to (1) designate the same person as the registrant (or its representative) as the technical contact; or (2) provide contact information which does not directly identify the technical contact person concerned.
*Note* (not part of the policy recommendation):
In its most recent deliberations, the EPDP Team:
* decided that it would be optional for the registered name holder to provide: technical contact name, email, and phone number * did not reach agreement on whether it would be optional or required for the registrar to offer the ability to the Registered Name Holder to provide these data elements,
The following groups expressed support for requiring registrars to provide the option for the RNH to provide tech contact data: IPC, BC, ALAC, SSAC, and GAC. The following groups expressed support for leaving it optional for registrars to provide the option for the RNH to provide tech contact data: RrSG, RySG and NCSG).
*Actions: P*lease indicate on the mailing list whether you have any concerns about these modifications. Additional discussion will occur as needed.
Deadline: Wednesday, 30 January, additional email discussion might follow depending on responses.
Thanks and best regards,
Kurt
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