On Legal vs Natural, any study must also consider the potential risks associated with NOT making the distinction. On the Org Field, the proposal is problematic. If the Registrar has received approval to publish the Org Field, it must be uniformly published. Alan At 31/01/2019 05:25 AM, Alan Woods wrote: Dear all, Apologies that this is late, but alas the never-ending email inbox did it's level best to hide this one on me! Particularly in response to Trang's helpful reminders that the Registry Operator's role requires some clarification in both the legal/natural and the Recommendation 9. To that end we suggest the following edits to Legal/natural (rather straightforward additions within the square brackets) and an additional standalone bullet point to Recommendation 9. Natural vs Legal The EPDP Team recommends that the policy recommendations in this Final Report apply to all gTLD registrations, without requiring Registrars [or registries] to differentiate between registrations of legal and natural persons, although registrars [and registries] are permitted to make this distinction. The EPDP Team recommends that as soon as possible ICANN Org undertakes a study, for which the terms of reference are developed in consultation with the community, that considers: * The feasibility and costs [(including both implementation costs and potential liability costs)] of differentiating between legal and natural persons * Examples of industries or other organizations that have successfully differentiated between legal and natural persons; * Privacy risks to registered name holders of differentiating and not differentiating between legal and natural persons; and * Other potential risks (if any) to registrars and registries of not differentiating. * The EPDP team will discuss the Legal vs Natural issue in Phase 2. Depending on the timing of the research, its discussions may inform the scope of research and/or use its findings. NOTE 1: The original recommendation alternates between 'distinction' and 'differentiation' for no apparent reason. It should be consistent, therefore we opted to use 'differentiate' throughout. NOTE 2: The second inclusion re implementation and liability is just to ensure there is clarity as to what 'costs' are being referred to. Recommendation 9 We suggest the addition of the following bullet point in Recommendation 9: * A Registry Operator, where they believe it feasible to do so, may publish or redact the Org Field in the RDDS output. Rationale: Although we defer to our registrar colleagues on this matter, the expectation of the registry operator's as a result of this, remain unclear. We therefore propose the bullet point to clarify our role. This inclusion highlights the still unreviewed and hugely problematic concept of the transfer of consent between Ry and Rr. The proposed recommendation allows for the publication of the Org at the 'Opt in' option of the registrant, and provides no further process, or clarification as to the onward application of this consent, and indeed makes no provision for adequate implementation of an Art 17 request to either the Ry or Rr. I have no doubt that this process will, in future, undergo technical and legal improvements, which may make this feasible for the registry to accept and apply the 'Opt-In' as obtained at the registrar level, but in the interim, our inclusion, although not purporting to affect the agreement reached for publication of the ORG field by a registrar, now also makes way for an optional publication by the RO (e.g. where a Registry Operator, who perhaps based on the specific model of the Rr (e.g. brand registrars etc) and/or based on other assurances provided to them, including the development and availability of prerequisite technology are satisfied, that the risk of data breach has been lowered to such an acceptable level, that the registry operator may choose to unredact the ORG field in the Registry RDDS output. Again apologies for delay in sending (happy to tee this up on a call), and thank you for the consideration. Alan Alan Woods Senior Compliance & Policy Manager, Donuts Inc. ________________________________ The Victorians, 15-18 Earlsfort Terrace Dublin 2, County Dublin Ireland <https://twitter.com/DonutsInc> <https://www.linkedin.com/company/donuts-inc> Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Donuts Inc. . Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you. On Mon, Jan 28, 2019 at 12:14 PM Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> > wrote: Alan, all, In relation to recommendation #9, please find attached the new thread that Kurt started on this topic with propose updated. You can also find the latest version of the language of recommendations under review, as well as deadlines here: https://community.icann.org/x/VZwWBg (see status of review doc at the bottom of the page). Best regards, Caitlin, Berry and Marika From: Alan Woods <alan@donuts.email> Date: Monday, January 28, 2019 at 03:50 To: "Mark Svancarek (CELA)" <marksv@microsoft.com<mailto:marksv@microsoft.com>> Cc: "James M. Bladel" <jbladel@godaddy.com<mailto:jbladel@godaddy.com>>, "Mueller, Milton L" <milton@gatech.edu<mailto:milton@gatech.edu>>, Alan Greenberg <alan.greenberg@mcgill.ca<mailto:alan.greenberg@mcgill.ca> >, Trang Nguyen <trang.nguyen@icann.org<mailto:trang.nguyen@icann.org> >, Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >, Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>, " gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Subject: [Ext] Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Hey all, Perhaps its the mountain of emails on umpteen topics, but I'm now lost on this recommendation. Perhaps someone refresh the thread with where the text of recommendation 9 now stands after all the back and forth? Thank you! Alan [donuts.domains]<https://urldefense.proofpoint.com/v2/url?u=http-3A__donuts.domains&d=DwMFaQ&...> Alan Woods Senior Compliance & Policy Manager, Donuts Inc. ________________________________ The Victorians, 15-18 Earlsfort Terrace Dublin 2, County Dublin Ireland [facebook.com]<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.facebook.com_donuts...> [twitter.com]<https://urldefense.proofpoint.com/v2/url?u=https-3A__twitter.com_DonutsInc&d...> [linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.linkedin.com_compan...> Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Donuts Inc. . Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you. On Thu, Jan 24, 2019 at 8:39 PM Mark Svancarek (CELA) via Gnso-epdp-team <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > wrote: That works for me. From: James M. Bladel <jbladel@godaddy.com<mailto:jbladel@godaddy.com>> Sent: Thursday, January 24, 2019 09:42 To: Mueller, Milton L <milton@gatech.edu<mailto:milton@gatech.edu>>; Alan Greenberg <alan.greenberg@mcgill.ca<mailto:alan.greenberg@mcgill.ca> >; Mark Svancarek (CELA) <marksv@microsoft.com<mailto:marksv@microsoft.com>>; Trang Nguyen <trang.nguyen@icann.org<mailto:trang.nguyen@icann.org> >; Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >; Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Taking all of these comments on board, as well as consulting other registrars, I think step 3.3 should provide Registrars the option to “delete” OR “redact” upon no response from the Registrant. Thanks� J. From: "Mueller, Milton L" <milton@gatech.edu<mailto:milton@gatech.edu>> Date: Thursday, January 24, 2019 at 6:09 AM To: Alan Greenberg <alan.greenberg@mcgill.ca<mailto:alan.greenberg@mcgill.ca> >, "Mark Svancarek (CELA)" <marksv@microsoft.com<mailto:marksv@microsoft.com>>, Trang Nguyen <trang.nguyen@icann.org<mailto:trang.nguyen@icann.org> >, "James M. Bladel" <jbladel@godaddy.com<mailto:jbladel@godaddy.com>>, Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >, Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>, " gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Subject: RE: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle We (NCSG) prefer deletion. If the registrant has been notified about the change and they choose not to respond, then they have chosen not to opt in. Under the principle of both data minimization and opt-in, the only legal path is to delete the information. --MM From: Gnso-epdp-team [ mailto:gnso-epdp-team-bounces@icann.org] On Behalf Of Alan Greenberg Sent: Wednesday, January 23, 2019 1:57 PM To: Mark Svancarek (CELA) <marksv@microsoft.com<mailto:marksv@microsoft.com>>; Trang Nguyen <trang.nguyen@icann.org<mailto:trang.nguyen@icann.org> >; James M. Bladel <jbladel@godaddy.com<mailto:jbladel@godaddy.com>>; Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >; Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle I prefer redaction as well. It means there needs to be a flag to indicate it can be publicly displayed, but I agree with the ICANN Org concern about losing potentially important imformation. Alan At 22/01/2019 06:25 PM, Mark Svancarek \(CELA\) via Gnso-epdp-team wrote: Regarding redaction/deletion, I think I prefer redaction. I defer to James whether redaction is technically more annoying than deletion. From: Trang Nguyen <trang.nguyen@icann.org<mailto:trang.nguyen@icann.org> > Sent: Tuesday, January 22, 2019 3:14 PM To: Mark Svancarek (CELA) <marksv@microsoft.com<mailto:marksv@microsoft.com>>; James M. Bladel <jbladel@godaddy.com<mailto:jbladel@godaddy.com>>; Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >; Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Dear All, Regarding the organization field, ICANN org flagged the following in the AC chat during the Toronto face-to-face meeting last week. We wanted to flag this again for your consideration/discussion as you work to finalize the recommendation: Some registrants use the organization field to identify themselves, an example of this is ICANN where the registrant name is â��Domain Administrator�râ� and organization is â��ICANNâ� †( https://www.godaddy.com/whois/results.aspx?domain=icann.org" [nam06.safelinks.protection.outlook.com] ;). Under 3(c) in Jamesâ€�s email below, if registrants do not respond the organizatioon field would be deleted. This could result in a number of registrations where identifying information for registrants would no longer be available. Itâ��s unclear if deletion is needed or whether redaedaction of the information would achieve the intent of the recommendation? Regarding the Natural vs. Legal recommendation, the proposed text of the recommendation says: â���without requiring Registrastrars to differentiate between registrations of legal and natural persons, although registrars are permitted to make this distinction.â� Is the intent of the recommendation to limit the requirement to registrars only, or should the text include registries as well? Best, Dan and Trang ICANN Org Liaisons From: Gnso-epdp-team < gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> on behalf of "Mark Svancarek (CELA) via Gnso-epdp-team" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Reply-To: "Mark Svancarek (CELA)" <marksv@microsoft.com<mailto:marksv@microsoft.com>> Date: Tuesday, January 22, 2019 at 8:32 AM To: "James M. Bladel" <jbladel@godaddy.com<mailto:jbladel@godaddy.com>>, Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >, Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>, " gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Makes sense, thanks for clarifying. From: James M. Bladel <jbladel@godaddy.com<mailto:jbladel@godaddy.com>> Sent: Tuesday, January 22, 2019 8:08 AM To: Mark Svancarek (CELA) <marksv@microsoft.com<mailto:marksv@microsoft.com>>; Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >; Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle I think we need to standardize on what the â��Registrant t Orgâ� field is telling us. Some registrars use thiis field to indicate that the Organization is the registrant, so if the end user deletes this information, it has the effect of re-assigning the name to natural person listed as the Registrant. J. From: "Mark Svancarek (CELA)" <marksv@microsoft.com<mailto:marksv@microsoft.com>> Date: Tuesday, January 22, 2019 at 8:05 AM To: "James M. Bladel" <jbladel@godaddy.com<mailto:jbladel@godaddy.com>>, Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >, Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>, " gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Subject: RE: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle I think I agree: can you clarify what this means? * Registration is re-assigned to Registrant (natural person) From: Gnso-epdp-team < gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of James M. Bladel Sent: Tuesday, January 22, 2019 6:30 AM To: Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> >; Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>; gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Hi Folks �< Letâ��s try to untangle this with the aim on simplicitcity & minimizing confusion (epdp and registrants). Here are my recollections from Toronto: Between the adoption of ePDP and some future date (Jan 1 2020?) Redact Registrant ORG field. Registrars contact Registrants who have data in this field, and ask them to confirm the data is correct & accurate. Based upon Registrant Action � 1. Registrant Confirms or Corrects � Data remains n Org field. > 2. Registrant Declines � Data in Org field is DELETED, Registration iss re-assiigned to Registrant (natural person) 3. Registrant No Response � Data in Org field is DELETED, Registrationn is re-assigned to Registrant (natural person) After future date � New registrations would present some disclosure/disclaimer when data is entered in the ORG field Registrars are free to innovate on the exact process, either an opt-in, or pop-up or locked/grayed out field, etc. ORG will be treated as the legal-person registrant of the domain name, with the Natural Person listed as a point of contact. ORG field will be published, if it contains data. From: Gnso-epdp-team < gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> on behalf of Marika Konings <marika.konings@icann.org<mailto:marika.konings@icann.org> > Date: Tuesday, January 22, 2019 at 6:02 AM To: Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>>, " gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Thanks, Sarah, for flagging this. We actually went back and forth on this looking at the transcript and our understanding was that opt-in was for existing registrations, while opt-out would apply to any new registrations (with the appropriate information being provided to the registrant that the information for the Organization field would be published, unless indicated differently). However, as this was Jamesâ��s proposal, we would like to ask him to confirm rm what the original proposal was so that the recommendation can be adjusted, as needed. James, over to you. Best regards, Caitlin, Berry and Marika From: Gnso-epdp-team < gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> on behalf of Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>> Organization: Tucows Date: Tuesday, January 22, 2019 at 05:36 To: " gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org>" <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Subject: Re: [Gnso-epdp-team] For your review - Proposed language for agreements reached in principle Good morning, I notice a significant difference between the Toronto Day 3 notes and the draft below, regarding the Organization field. Day 3 notes - "Principles for Redaction of Registrant Organization Field" #4: 4. Upon (1) the registration of a Registered Name sponsored by Registrar or (2) the transfer of the sponsorship of a Registered Name to Registrar, the Registrar MUST inform all Registered Name Holders that the Registrant Org field will be redacted unless the Registered Name Holder affirmatively opts in to the publication of the Registrant Org field. Updated Recommendation #9 below: 4. Upon (1) the registration of a Registered Name sponsored by Registrar or (2) the transfer of the sponsorship of a Registered Name to Registrar, the Registrar MUST inform the Registered Name Holder that the Registrant Org field will be published unless the Registered Name Holder affirmatively opts in to redaction of the Registrant Org field. The Org field should be redacted by default, and the Registered Name Holder should be able to opt-in to publication. This aligns with the principle of Privacy by Default and is what we agreed on during the Day 3 meeting. Thanks, -- Sarah Wyld Tucows +1.416 535 0123 Ext. 1392 On 1/22/2019 12:33 AM, Marika Konings wrote: Dear EPDP Team, In Toronto, we reached agreement in principle on several issues but did not have time to develop language to which the team agreed. To move that discussion forward, the support team has developed the proposed language below for discussion and inclusion in the Final Report. Please review this language with your group to ensure it aligns with the agreement that was reached. If you are of the view that it does not conform to the agreement, please: Respond to this message and change the subject line to the topic of the recommendation about which you have concerns; Outline your concerns, focusing on how the proposed language does not reflect the principle agreement reached, and; Propose edits that would address your concerns that are in line with the agreement reached. The deadline for doing so is Thursday 25 January so that there is sufficient time to review and discuss any concerns. If no concerns are raised, this language will be incorporated into the draft Final Report for your review. Best regards, Caitlin, Berry and Marika ========= Based on the discussions during the F2F meeting in Toronto, the following updated language is provided for EPDP Team review on the following topics / recommendations: Natural vs. legal Draft recommendation1) The EPDP Team recommends that the policy recommendations in this Final Report apply to all gTLD registrations, without requiring Registrars to differentiate between registrations of legal and natural persons, although registrars are permitted to make this distinction.2) The EPDP Team recommends that as soon as possible ICANN Org undertakes a study, for which the terms of reference are developed in consultation with the community, that considers: * The feasibility and costs of distinguishing between legal and natural persons; * Taking into account examples of industries or other organizations where this has been successfully done; * Consider privacy risks to registrants, and; * Consider the risks of not differentiating. 3) Depending on the timing of the research, whether to inform the scope or make use of its findings, the EPDP team will discuss the Legal vs Natural issue in Phase 2. Consent to publish additional contact information Agreement in principle: In its discussion on consent, the Temporary Specification omitted RNH email as a piece of information to which the registrant could consent to publication. This draft recommendation corrects that omission. Draft recommendationThe EPDP Team recommends that, as soon as commercially reasonable, Registrar must provide the opportunity for the Registered Name Holder to provide its Consent to publish additional contact information. Organization Field Agreement in principle: Rather than requiring the publication or redaction of the Organization Field, a phased approach was suggested by Team Members that gained general agreement. Updated Recommendation #9 1. The EPDP Team recommends that Registrars MAY begin redacting the Registrant Org field immediately.2. For existing registrants: the EPDP Team recommends that Registrars MUST notify all existing Registered Name Holders that the Registrant Org field will be treated as non-personal data for new registrants beginning on [x date - to be agreed upon during the implementation of this Policy], and accordingly, the field will be published for new registrants in the freely-accessible directory beginning on [x date]. However, if existing Registered Name Holders wish to have its Organization field published within the freely-accessible database, it must affirmatively consent to the publication by opting in. If the Registered Name Holder affirmatively opts in to the publication of its existing (or modified) Registrant Organization, the Registrar may publish the Registrant Organization Field immediately and/or on the agreed-upon [x] date.3. The EPDP Team recommends if the existing Registered Name Holder does not affirmatively opt in to the publication of its Registrant Organization field, the Registrar will show the existing Registrant Organization Field but the field MAY be left blank.4. Upon (1) the registration of a Registered Name sponsored by Registrar or (2) the transfer of the sponsorship of a Registered Name to Registrar, the Registrar MUST inform the Registered Name Holder that the Registrant Org field will be published unless the Registered Name Holder affirmatively opts in to redaction of the Registrant Org field. Deferring consideration of new proposed purposes to phase 2 Agreement in principle: With regards to proposed Purpose O, the Purpose supporting ARS, and the additional purposes received through public comment, the EPDP Team understands some legal clarification is required as to whether those purposes can fall under existing Purposes. Additional complexities were introduced. Therefore, the Team decided to put off this discussion for Phase 2 where the EPDP Charter makes it clear that additional Purposes are, in fact, anticipated. Draft recommendationThe EPDP Team commits to considering in Phase 2 of its work whether additional purposes should be considered to facilitate research carried out by ICANNâ��™s Office of the Chief Technology Officer (OCTO) as well as the continuation of the WHOIS Accuracy Reporting System (ARS). This consideration should be informed by legal guidance on if/how provisions in the GDPR concerning research apply to ICANN Org. Marika KoningsVice President, Policy Development Support � GNSO, Internet Corporatioon for Assigned Names and Numbers (ICANN) Email: marika.konings@icann.org<mailto:marika.konings@icann.org> Follow the GNSO via Twitter @ICANN_GNSOFind out more about the GNSO by taking our interactive courses [nam06.safelinks.protection.outlook.com]<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense...> and visiting the GNSO Newcomer pages [nam06.safelinks.protection.outlook.com]<https://nam06.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense...>. _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org<mailto:Gnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team [nam06.safelinks.protection.outlook.com] [ nam06.safelinks.protection.outlook.com [nam06.safelinks.protection.outlook.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__nam06.safelinks.protecti...>] _______________________________________________Gnso-epdp-team mailing listGnso-epdp-team@icann.org<mailto:listGnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team [nam06.safelinks.protection.outlook.com] _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org<mailto:Gnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team ---------- Forwarded message ---------- From: Kurt Pritz <kurt@kjpritz.com<mailto:kurt@kjpritz.com>> To: EPDP <gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> > Cc: Bcc: Date: Fri, 25 Jan 2019 11:13:26 -0800 Subject: [Gnso-epdp-team] Organization Field - Updated - Recommendation #9 Hi Everyone: In the ongoing and seemingly never-ending attempt to close discussion on Recommendations for the Final Report via email discussion, below please find amended wording for Recommendation 9, having to do with the publication / redaction of the Organization field. After posting of the initial version, I read the email list comment and was drawn to James’ rather clean outline, as opposed to my less clear earlier proposal. Therefore, I took the liberty of reorganizing the proposed Recommendation somewhat, taking into account not only James structure but also the email comments before and after that (as well as the meeting notes). The result is below. I also placed the procedure itself as part of our “implementation advice” as there will be operational details to figure out. The implementation effort can ensure that those “details” are consonant with the policy goals. Proposed Recommendation #9 The EPDP Team recommends that: - The Organization field will be published if that publication is acknowledged or confirmed by the registrant via a process that can be determined by each registrar. If the registered name holder does not confirm the publication, the Organization field can be redacted or the field contents deleted at the option of the registrar. - The implementation will have a phase-in period to allow registrars the time to deal with existing registrations and develop procedures. - In the meantime, registrars will be permitted to redact the Organization Field. Implementation advice: the implementation review team should consider the following implementation model discussed by the EPDP Team: For existing registrations, the first step will be to confirm the correctness / accuracy of the existing Organization field data. For the period between the adoption of EPDP policy recommendations and some future “date certain” to be determined by the implementation review: 1) Registrars will redact the Organization field 2) Registrars will contact the registered name holders that have entered data in the Organization field and request review and confirmation that the data is correct. a. If the registered name holder confirms or corrects the data the data will remain in the Organization field. b. If the registrant declines, or does not respond to the query, the Registrar may redact the Organization field, or delete the field contents. If necessary, the registration will be re-assigned to the Registered Name Holder. 3) If Registrar chooses to publish the Registrant Organization field, it will notify these registered name holders that of the “date certain,” the Organization field will be treated as non-personal data and be published, for those Registered Names Holders who have confirmed the data and agreed to publication. For new registrations, beginning with the “date certain”: 1) New registrations will present some disclosure, disclaimer or confirmation when data is entered in the Organization field. Registrars are free to develop their own process (e.g., opt-in, pop-up advisory or question, locked/grayed out field). 2) If the registered name holder confirms the data and agrees to publication: a. the data in the Organization field will be published, b. The Organization will be listed as the Registered Name Holder. c. The name of the registered name holder (a natural person) will be listed as the point of contact at the Registrant Organization. Actions: Please indicate on the mailing list whether you have any concerns about these modifications and/or what other aspects of this recommendation should be discussed. Deadline for comment: Tuesday 29 Jan. Thank you and best regards, Kurt