Dear RDRS Standing Committee members,
Please find below the notes and action items from today’s meeting.
Congratulations to all on the hard work it took to get to this point.
Best regards,
Caitlin on behalf of the RDRS SC Support Team
--
RDRS Standing Committee Meeting
11 August 2025
Action Items
Agenda
·
This will be the last call prior to publication of our draft report for public comment
o
Draft
Report [docs.google.com]
·
As an outcome from the last meeting, Support Staff made some updates to the recommendations.
·
The main pending discussion item relates to Rec. 14 (financial considerations) - specifically the table.
·
Gabe proposes to change the action from “keep” to “modify”
·
14.5.1 should be modified:
·
14.5. In relation to the accreditation framework:
·
14.5.1. Accreditation applicants MUST be charged a to-be-determined non-refundable fee proportional to the cost of validating an application, except under certain circumstances these fees may be waived
or zero for certain types or categories of applicants which SHOULD be further defined during the implementation phase.
·
Want to avoid a situation where Interpol, FBI, or other public safety agencies are required to charge fees if they accredit their constituent groups when they may not want to.
·
Open to accreditation-related fees being modified.
·
If that is what we are proposing, would like to see that made very clear in the report.
·
Proposed text: The Standing Committee notes that the considerations in Recommendation 14.5 relating to the accreditation framework may need to be adjusted depending on specifics determined by the accreditation
provider.
·
Could add “for example, public safety agencies acting for their constituent members.”
·
“Specifically, the Standing Committee notes that the considerations in Recommendation 14.5 relating to the accreditation framework may need to be adjusted depending on specifics determined by the accreditation
provider. For example, public safety agencies may choose to waive fees for their constituent members.”
·
This discussion about fee waiver is re: 14.5 only.
·
This group has discussed Rec. 14 at length. The group discussed they would leave it alone, with the exception of 14.5. The articulated disagreements to parts of Rec. 14 are included in the Lessons Learned
section of the report.
·
On previous calls, we discussed a possible enhancement for a link in RDRS with non-participating Rrs with their own request system. It would be a good enhancement to add this. Even if there isn’t agreement
to include that in recommendations, recommend adding this to lessons learned.
·
Support staff can include this in assignment 2 for a future enhancement. Would the SC like to add this to a recommendation? If so, the enhancements may need to be reranked?
·
Recommend putting this as an enhancement and not adding as a recommendation this late in the day.
·
Thought that in RDRS if the Rr for the desired domain name is not participating, the RDRS would say - sorry, can’t use RDRS, but here is the info that they passed along for your reference - phone number,
email, link to form, as applicable.
·
Right now, if there is a non-participating registrar, that is as far as you can go. Without a significant amount of effort, we can do better. Registrars are required to provide information and mechanisms
for requesting access to non-public data.
·
The text highlighted on the left re: prima facie review, this text may be too prescriptive in terms of telling registrars exactly what they have to do and how they have to do it. Some of these steps
may be unnecessary. That said, all of this may be pointless if this text was suggested for removal anyway.
·
The text in this paragraph is not a lesson learned or suggested enhancement. There could be something better done with communication about decisions, but the copy/paste of the recommendation makes it
unclear. The Standing Committee cannot change the requirements.
·
One lesson learned is that we don’t know how registrars come to their decision to make the disclosure or not. NCSG believes that fundamental rights balancing should happen. If the Rr does not want to
do fundamental rights balancing, it should be documented why.
·
This text is part of Assignment 3, part of lessons learned, so SC is free to note disagreement here.
·
Re: the table - comments on p. 19 re: clarification on new text.
·
Disclosure must occur if a lawful basis exists, provided the human rights must be taken into account. The words “if applicable” don’t make sense here - when is human rights not applicable?
·
Human rights may not be impacted if it doesn’t lead to unfair arrest or chilling right of expression.
·
Suggest rephrasing “potential violation of human rights must be taken into account.” Do not want to imply that there are people who do not have human rights.
·
Follow-on question - there are entities that have tried to obtain Rr status before but espouse views in which they highly value privacy above all other rights. Does this suggest that as long as a Rr can
suggest that, they could always deny every request for disclosure?
·
This paragraph is just meant to make it transparent why a request is denied, and it should be documented. If a registrar feels they are given carte blanche to deny every request, it is possible that a
registrar could reject based on its fundamental rights balancing. If a registrar does this repeatedly, we will know.
·
Fear that if there is a MUST for a registrar to call out that the human rights assessment, you may be putting registrars in a risky situation with authoritarian regimes. Allowing registrars the option
to do this and have flexibility to not be targets to authoritarian regimes.
·
We are not prescribing how the documentation should take place.
·
Either the requestor and Rr both subscribe to the human rights convention, or they do not.
Consensus Call
·
While the consensus call will be opened today on the recommendations, other text and clarifications if non-substantial can be considered throughout the week.
·
Do not object to text submitted by Farzaneh, but would like to confirm the text matches what it is in the ODA.
·
Following this call, Sebastien will send the consensus call via email – 11 August. The consensus call applies to the recommendations only. Per Marc’s request last week, the recommendations have been reordered.
·
Leadership has designated all recs as full consensus.
·
The consensus call will close at
23:59 UTC on Friday, 15 August.
·
If you agree with what is on screen/later in email, no action is needed. If you disagree, please indicate your disagreement by the deadline (Friday, 15 August).
·
Only members of the SC are to participate in this consensus call.
·
Support Staff will provide a PDF of just the recommendation text so that it is clear what the group is being asked to review.
·
Understand that this is the consensus of this team, not the constituent groups.