Dear EPDP Phase 2 team, We are sharing the below and attached from Karen Lentz, Senior Director, Policy Research & Data Services. Thank you, Eleeza and Dan ICANN org liaisons ----------------------- Dear colleagues, Attached is ICANN org’s analysis in response to the EPDP Ph 1 Recommendation 15.4 on the data retention waiver procedure. A summary of the key points is below: * ICANN org was asked to perform a review the current data retention waiver procedure. In line with the recommendation, the goal of the analysis is to assess the data retention waiver request process with a particular focus on request response times, GDPR compliance, and overall efficiency of the process. * The analysis shows that waiver request response times decreased significantly since the first request was received in September 2013, from an average of 464 days in the early period of the request process, to 62 days in the latter. * Decreased response times were driven by experience and the ability to evaluate each subsequent request from the same jurisdiction using the same legal grounds as previous requests. In general, a request received from the same jurisdiction as a previous request took less time than the first as familiarity with applicable law increased. * As the EPDP Phase 2 team will be addressing charter questions related to data retention, ICANN org is not recommending any changes to the procedure while this work is ongoing. Note that a related analysis in regard to Recommendation 15.1 on data retention<https://mm.icann.org/pipermail/gnso-epdp-team/2019-November/002747.html>, was shared with the EPDP Phase 2 team in November. We hope the above is helpful; please let us know of any additional questions. -- Karen Lentz Senior Director, Policy Research & Data Services ICANN 12025 Waterfront Drive, Suite 300 Los Angeles CA 90094 +1 310 895 3637