July 2019 - IRT.RegDataPolicy

Meeting schedule
by Sarah Wyld 07 Aug '19

07 Aug '19

Hello Dennis and Team, Should we consider moving to weekly 1-hour meetings, instead of 1.5 hours every two weeks? This may help us maintain momentum and finish our work closer to our deadline. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392

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Rec19 Analysis Review
by Dennis Chang 31 Jul '19

31 Jul '19

Dear IRT, Recommendation 19 Analysis is ready for your review and added to the IRT Task list as 30 Review Recommendation 19 Analysis<https://docs.google.com/document/d/1kJFdfch4WI-bE8zXW1EM8ioVOAg7BlPOimJkqYJ…> 20190814 You’ll note that we are skipping Rec 18 for now and will come back to it later. Next Rec 20, 21, 22 are coming up. Thank you for your continuing support of this policy implementation. Regarding the IRT meetings, we note that some suggested a weekly IRT meetings. I’ll add this to the agenda for next week’s meeting. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>

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Tech contact consent
by Sarah Wyld 28 Jul '19

28 Jul '19

Hello team, There is some great discussion in the Google Doc (https://docs.google.com/document/d/1OuZT7xL5wuV1ynVmpVNxFycU93gvPlvbzx_g9lX…) about the possibility for the Tech contact to consent to publication of their data (name, phone and email), but I think it's a bit easier to consider it by email, so I will start this discussion and look forward to hearing what everyone else thinks. I see it as two separate questions, one of which is already resolved and the other remaining open. *1 - can the RNH grant consent for publication of Tech contact data? * Based on comments in the doc (including mine) and Dennis's subsequent changes, there is agreement that it is not possible for one person to consent to publication of another person's data. So, if the RNH is also the Tech contact, then maybe they could grant consent (if it's possible in an automated manner for the registrar to know that these contacts are the same, which may not be possible) but certainly if it's a different person then this is not an option. *2 - can the Tech contact grant consent for publication of its own data? * Although on the surface this sounds straightforward, I think it's actually a problem. There is no Recommendation in the Phase 1 final report relating to the Tech contact granting consent. Rec 5 explains what the tech contact may be ("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.") Rec 6 requires that the RNH can consent to publication ("The 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 redacted contact information, as well as the email address, in the RDS for the sponsoring registrar.") Rec 10 requires that the tech contact is redacted. Rec 13 refers again to the RNH consenting to publication of their data ("1) The EPDP Team recommends that the Registrar MUST provide an email address or a web form to facilitate email communication with the relevant contact, but MUST NOT identify the contact email address or the contact itself, unless as per Recommendation #6, the Registered Name Holder has provided consent for the publication of its email address.") Additionally, the Registrar may not have a legal basis on which to publish the Tech contact data (again, assuming it is not known to be the same as the RNH data). There is no contractual relationship between the registrar and the tech contact, so 'performance of a contract' cannot be the basis for publication, and because there is no contractual relationship it would be improper for the registrar to communicate with the tech contact (the registrar does not have any legal basis on which to process the tech contact's data) even just to send them an email about this consent request. As such, for question 2 the answer should be no, *the Tech contact cannot grant consent to publish their data*. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392

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IRT Call Agenda - 24 July 2019
by Amr Elsadr 24 Jul '19

24 Jul '19

Hi Dennis, I missed the last IRT call on July 10th, when recommendations 5 through 9 were meant to be on the agenda. Looking at the [agenda for today’s call](https://community.icann.org/display/RDPIRT/2019-07-24+Registration+Da…, it seems the same recommendations are still up for discussion. Apologies for missing the last call (and honestly, haven’t had time to watch the recording), but could you please confirm today’s (well…, today in a UTC +2 timezone) agenda? If we’re still on policy language for recommendations 5 through 9, what are the outstanding action items concerning them? Thanks. Amr

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Rec 16&17 analysis review
by Dennis Chang 19 Jul '19

19 Jul '19

Dear IRT, Recommendation analysis for Rec #16 and 17 are ready for your review and added to the IRT Task list as: 28 Review Recommendation 16&17 Analysis<https://docs.google.com/document/d/1zF45EV9YhCMTkg7rfk81Hbga26Qj_PyO8PG9EC-…> 20180802 With these two recommendations, the policy language turned out to be simple. There are directions in the recommendation for studies and notes for EPDP Team. Reminder: Column E in the IRT workbook contains the IPT planned actions for the tasks that https://docs.google.com/spreadsheets/d/1r8yMMEFIFS-KHGMsnLdVbdn0O_GWhf7vNLl… — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>

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Review Rec15 Analysis
by Dennis Chang 17 Jul '19

17 Jul '19

Dear IRT, Recommendation 15 Analysis is ready for your review and added to the IRT Task list as 27 Review Recommendation 15 Analysis<https://docs.google.com/document/d/14vgbEK8D8dfpbGJp8GRfvAsWDD34RCJ0OEj7A7q…> 20190731 Thanks for the great support and collaboration. Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>

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Review Rec14 Requirement
by Dennis Chang 15 Jul '19

15 Jul '19

Dear IRT, Recommendation 14 policy language is ready for your review and added to the IRT Task list as: 26 Review Recommendation 14 Analysis<https://docs.google.com/document/d/1LVRC3qDxbOCtKs5TupX-S7MIYeoXPplPpdMT44K…> 20190729 For this one, we’ve decided to keep it as a separate document for now but you will see that we intend to add it later to the Publication section. Thanks always for keeping up with the assignments. Rec 15 coming up next. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>

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Follow up on IRT meeting discussion - recommendation 7
by Anderson, Marc 15 Jul '19

15 Jul '19

Team, I'm writing to follow up on the discussion we began toward the end of last Wednesday's IRT call on Recommendation #7, and specifically what the intention of that recommendation was. The EPDP Phase 1 Final Report makes it very clear that the registrant data elements (as well as the tech and name server data elements) enumerated in section 6.2 of the draft consensus policy are OPTIONAL for the registrar to transfer to the registry. The recommendation text makes reference to the data elements workbooks that were included in Annex D of the Final Report, which further clarify that the transfer of these data elements from the registrar to the registry is optional based on the policies, terms and conditions of the registry. During the call on Wednesday, there was some confusion about this topic and there was an assumption made by some that if these data elements are collected by the registrar, then they must be transferred to the registry - however, this is not what Recommendation #7 states or means. If the registry requires the data elements per its policies, terms or conditions, AND there is an appropriate legal basis and data processing agreement in place between the registry and its registrars, then (and only then) must the registrar transfer the data elements. However, if the registry does NOT require the data elements, then the registrar is NOT obligated to transfer those data elements to the registry. That is what the "optionality" under the "transfer logic" of the table in Recommendation #7 refers to. It's also worth noting that in the Scorecard that accompanied its resolution on the Phase 1 recommendations, the Board asks the EPDP to consider "whether the suggested corrections contained in the RySG's comments and the accompanying chart in Appendix G more accurately reflect the Phase 1 consensus". When the RySG developed those comments, we recognized that the recommendation text was potentially confusing, so we suggested a more clear way of presenting the recommendation. I'm including that at the bottom of this email so you can all review. I believe this more accurately reflects the expressed intention of Recommendation #7 and may be useful to ICANN staff in thinking about how to re-draft this part of the policy appropriately. Thanks, Marc RySG Chart: Data Elements Transferred from Registrar to Registry Domain Name REQUIRED to be transferred from Registrar to Registry Registrar Whois Server REQUIRED to be transferred from Registrar to Registry Registrar URL REQUIRED to be transferred from Registrar to Registry Updated Date REQUIRED to be transferred from Registrar to Registry Registrar Registration Expiration Date OPTIONAL to be transferred from Registrar to Registry Registrar REQUIRED to be transferred from Registrar to Registry Registrar IANA ID REQUIRED to be transferred from Registrar to Registry Registrar Abuse Contact Email REQUIRED to be transferred from Registrar to Registry Registrar Abuse Contact Phone REQUIRED to be transferred from Registrar to Registry Reseller OPTIONAL to be transferred based on Registry policies Domain Status(es) REQUIRED to be transferred from Registrar to Registry Registrant Fields * Name REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Organization OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Street REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * City REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * State/province REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Postal code REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Country REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Phone REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Phone ext OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Fax OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Fax ext OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Email Required to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element Tech Fields * Name OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Phone OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Email OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element Name Server OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided DNSSEC OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided Name Server IP Address OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided * Additional data elements as identified by Registry Operator in its registration policy, such as (i) status as Registry Operator Affiliate or Trademark Licensee [.MICROSOFT]; (ii) membership in community [.ECO]; (iii) licensing, registration or appropriate permits (.PHARMACY, .LAW] place of domicile [.NYC]; (iv) business entity or activity [.BANK, .BOT] REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require these data elements

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Rec 9 Analysis Review
by Dennis Chang 15 Jul '19

15 Jul '19

Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweK…> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweK… Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>

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Review Rec12 Analysis
by Dennis Chang 14 Jul '19

14 Jul '19

Dear IRT, Rec 12 analysis and corresponding policy language Is now available for your review and added to the IRT Task list as: 25 Review Recommendation 12 Analysis<https://docs.google.com/document/d/1OuZT7xL5wuV1ynVmpVNxFycU93gvPlvbzx_g9lX…> 20190728 For Rec 12, we did not create a new document but rather added to the existing Rec 10, 11, and 13 document. I’ve marked the requirements as [Rec 12] for section 8.6 and 8.7. So, now we have in one document, Rec 10, 11, 12, and 13. To make it simpler to track, I’ve revised the Rec 10 due date to 28 July to be consistent with Rec 12. Thank you for your continued support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>

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