Hi All,

First, I want to reiterate my thanks to ICANN Staff for the excellent work on the public comment analysis and report. The fact that we have exited a public comment period on this with so few changes and so (SO) close to being finished is a credit to the entire IRT/IPT.

Second, I support Sarah’s points. I also note that the requests under this section require manual processing, analysis and response, which necessitates more time to review. ‘Business days’ were discussed at length and chosen to adhere to Rec 18 as well as to provide clear guidance across jurisdictions. Further, the rationale in Section 3 of the Addendum to the Public Comment Report, states that in response to multiple comments the IPT did not feel the timeline reflect the nature of “urgent requests”, but it doesn’t offer a rationale to support that conclusion. We discussed this at great length during the IRT process and the team agreed upon business days.

Best,
Beth

From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> on behalf of Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org>
Date: Wednesday, May 10, 2023 at 1:29 PM
To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org>
Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] IRT Task 236 Review updated Policy Language -post Public Comment due 20230517

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Hello all,

As provided on the call just now, my feedback on 10.6 Urgent Responses: 24 hours is not faithful implementation of the recommendation.

The Phase 1 EPDP WG did not specify the exact timeframe but they provided a framework for the implementation team to use.
The Phase 1 EPDP WG could have settled on 24 hours but did not; we can't say this must have been their intent.
Phase 1 Rec 18 said "business days", it must be business days, not calendar days or hours. The IPT expressed concern that business days vary by region, but this could instead be the reason that the Phase 1 EPDP WG chose business days instead of calendar days. Implementing as anything other than business days is not implementing the Recommendation faithfully.
Phase 1 Rec 18 said "business days", plural, they considered a minimum of 2 to fill in that X, otherwise it would have just said "day" singular
Phase 1 Rec 18 used square brackets to indicate that the phrase "[less than X business days]" goes together as a unit and that this is the timeframe which needs to be specified. It is not (round brackets) to indicate it as a side thought or throwaway idea.
RAA requirements for Abuse Reports are for different a thing and are handled differently (and often by a different team) than disclosure reports. The Phase 1 EPDP WG was aware of this requirement and could have made urgent disclosure requests be 24 hours if they wanted to, they did not.
This is the maximum, not standard. The expectation is to respond without undue delay.

We must stick with 2 business days.

--

Sarah Wyld, CIPP/E

Policy & Privacy Manager

Pronouns: she/they

swyld@tucows.com

From: Dennis Chang via IRT.RegDataPolicy
Sent: May 4, 2023 10:13 AM
To: Anderson, Marc via IRT.RegDataPolicy
Subject: [IRT.RegDataPolicy] IRT Task 236 Review updated Policy Language -post Public Comment due 20230517

Dear IRT,

We’ve completed review of all public comments and made the updates to the policy language.

Prepared are the redline version and the clean version for your review.

The Registration Data Policy with redlined changes resulting from Public Comment: Registration Data Policy - Redline Version Post Public Comment
The clean version of the Registration Data Policy with changes resulting from Public Comment: Registration Data Policy - CLEAN Version Post Public Comment

Also prepared is the Public Comment Report Addendum that documents the analysis and responses for the comments.

Public Comment Report - 20 January 2023
Public Comment Report Addendum - Responses to Registration Data Public comment - 28 April 2023

You will find all these documents posted on the IRT wiki following our normal process. https://community.icann.org/display/RDPIRT/RegDataPolicy+Implementation+Resource+Documents

We’ll go over these in the IRT meeting on 10 May 2023.

Kind Regards,

Dennis S. Chang

GDD Programs Director

Phone: +1 213 293 7889

Sykpe: dennisSchang