When we mention the ARS program what exactly does that entail? The current/pre-GDPR WHOIS ARS program was far from GDPR compliant, including ICANN ORG making robocalls to registrants and emailing registrants to verify the email address correctness. Apologies if I missed the memo on this subject explaining all this. Thanks Theo On 24-1-2019 14:50, Alan Greenberg wrote:

I offered to suggest a wording change to Purpose 5 to allow it to include the Accuracy Reporting System (ARS) as previously suggested by Milton.

Add to rationale:

To allow ICANN to carry out accuracy audits of registration contact data, ICANN may request from Registry Operators and Registrars the minimum data for randomly selected registrations.

Under F-PA2 replace "ICANN org compliance" with "ICANN org" (2 places)

Under F-PA4 replace "ICANN Compliance" with "ICANN org" and add to Lawful Basis "May go beyond the life of registration in order to complete accuracy audit and compliance processing, not to exceed one year."

Data element table will need to include any contact information still in use post EPDP.

Alan

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