Hello All,

The RySG appreciates the RrSG’s proposal regarding changes to the Urgent Request Section language proposed by ICANN, however, Registries believe that the original ICANN language, with minimal changes, is a more straightforward approach that can also address RR concerns. We believe that the edited language below, combined with the shared agreement among the IRT that any actions under this language are based solely on the establishment of a mutually agreed authentication system for law enforcement, negates the need to add the additional procedural language.

 

For more context, this also assumes that the authentication system (the System) currently being developed by the IRT/PSWG Small Group will:

1-Be specific to use by law enforcement and that law enforcement will be defined as part of the System;

2-The Terms and Conditions of an authenticated law enforcement user of the System will include requirements for said user to have done their due diligence to ensure the request received is in fact “urgent” and lawful. 

 

If the requests Contracted Parties receive have been subject to this rigor, we don’t think that the more specific additional language is required. In addition, we believe that requests meeting this level of rigor would not require more than 24 hours to respond. 

 

Looking forward to discussion during our next meeting. Please find the redline attached.

 

Thank you,

RySG

 

 

 

From: Elizabeth Bacon <bbacon@pir.org>
Date: Monday, July 14, 2025 at 10:15
AM
To: Sarah Wyld <swyld@tucows.com>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org>
Subject: Re: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests

Hello All,

Just a note that the RySG is currently considering and will weigh in this week re: Urgent Requests.  We had several team members at conferences following Prague, so we apologize for the delay.

 

Many thanks,
Beth

 

From: Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org>
Date: Friday, June 27, 2025 at 3:36
PM
To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org>
Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests

Hello IRT Team,

The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy.

I have attached a PDF of the suggested language, and you can also find a Google Doc copy here (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment).

I hope that this is a helpful step forward in our discussion.

Thank you,

--

Sarah Wyld, CIPP/E
Pronouns: she/they

Head, Policy & Privacy
Tucows #MakingTheInternetBetter

swyld@tucows.com

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