Hi Sarah, Thank you for the pointing this out. Implementation Note K a. is meant to reference the Urgent Request requirements in Section 10.7. This has been updated in the public comment draft. Also, thank you Beth for the well wishes, it was a pleasure working with you all on this effort. Best, -- Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<http://www.icann.org> Mobile: +1 310 266 7469 From: "Sarah Wyld via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org> Organization: Tucows Reply-To: Sarah Wyld <swyld@tucows.com> Date: Tuesday, October 21, 2025 at 9:28 AM To: "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Updated October 2025 ICANN org proposed language for IRT feedback prior to public comment period. Hello IRT! I am reviewing the Implementation Note K and I see it refers to "The obligations under Section 3.7". Is this the correct section number? Reg Data Policy:
3.7. "Reasonable Requests for Lawful Disclosure" ("Disclosure Requests") refers to requests submitted to a Registry Operator or Registrar for the disclosure of non-public Registration Data in accordance with the requirements of Section 10.
That is already effective, so should Note K instead refer to maybe 3.8 (definition of Urgent) or 10.7 (Urgent request requirements and timeframe language)? Sarah Wyld, CIPP/E Pronouns: she/they Head, Policy & Privacy Tucows #MakingTheInternetBetter swyld@tucows.com<mailto:swyld@tucows.com> Responses to this email are processed according to the Tucows Privacy Policy<https://www.tucows.com/privacy> On 2025-10-17 5:47 p.m., Isabelle Colas-Adeshina via IRT.RegDataPolicy wrote: Dear IRT, Thank you for your feedback and input. We appreciate your continued support in this process. We plan to move forward with posting the October 3rd draft to public comment. In consideration of the GAC’s concern we plan to pose this question to the community during public comment for additional feedback. The IRT has discussed the proposed Section 10.7 and some IRT members believe the authentication mechanism (when available) would require additional policy work, while others believe the authentication mechanism is part of the implementation of Recommendation 18 and would not require additional policy work. Do you believe this requires additional policy work? If you believe this requires additional policy work, please explain. If you do not believe this requires additional policy work, please explain. As a reminder, I highly encourage everyone to provide input during the public comment period. The public comment period will provide a transparent opportunity for IRT members as well as other stakeholders to share feedback on the proposal. The public comment also provides the opportunity to raise alternative suggestions that have not already been discussed that can be transparently shared with the community. We will review the public comment submissions for new concerns and suggestions which can be considered in the next phase of drafting. Following public comment review, we will propose next steps with the IRT based on the feedback received. Thank you again , -- Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<http://www.icann.org> Mobile: +1 310 266 7469 From: "Sarah Wyld via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Organization: Tucows Reply-To: Sarah Wyld <swyld@tucows.com><mailto:swyld@tucows.com> Date: Friday, October 17, 2025 at 12:55 PM To: "irt.regdatapolicy@icann.org"<mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Updated October 2025 ICANN org proposed language for IRT feedback prior to public comment period. Hello all, The RrSG is also ready to move to public comment with the 3 October draft, but cannot review the input submitted today which was not considered by the IRT during our meetings. Thank you Sarah Wyld, CIPP/E Pronouns: she/they Head, Policy & Privacy Tucows #MakingTheInternetBetter swyld@tucows.com<mailto:swyld@tucows.com> Responses to this email are processed according to the Tucows Privacy Policy<https://www.tucows.com/privacy> On 2025-10-17 3:45 p.m., Elizabeth Bacon via IRT.RegDataPolicy wrote: Hello All, The RySG has reviewed ICANN’s proposed language (as linked below) and supports moving it forward to public comments. We aren’t able to comment on the edits proposed today as there wasn’t time to reconvene the RySG to discuss. Thank you, Beth on behalf of the RySG From: CAROLILLO Gemma via IRT.RegDataPolicy <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Date: Friday, October 17, 2025 at 11:37 AM To: Isabelle Colas-Adeshina <isabelle.colasadeshina@icann.org><mailto:isabelle.colasadeshina@icann.org>, irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Updated October 2025 ICANN org proposed language for IRT feedback prior to public comment period. Dear Isabelle, dear IRT Members, We discussed the state of play and the latest text in the GAC small team on registration data and we find the work of the IRT is going in the right direction. I am conveying the appreciation of the whole team for the good cooperation in the IRT group. Before the text is finalised and sent for public comment, we would propose that one outstanding element be addressed concerning the institutionalisation of the authentication system. We believe the latest text circulated by ICANN org attempts to achieve a shared goal – that is reaching certainty in the implementation and enforcement of the policy. However, we are concerned that as the text stands now it might imply that a new policy development process would be required to include the authentication system in the registration data policy. This is why we propose a text that we believe provides more flexibility. You will find more details in the rationale attached to the proposed text, but from the GAC perspective a new PDP is neither necessary nor desirable. We are already at the stage of implementing consensus policy (EPDP Phase 1 recommendations) and it was upon request of the ICANN Board and the GNSO Council that the issue of authentication was addressed in parallel to the establishment of a timeline. The GAC has agreed to this request and accepted that the PSWG would devote resources to work with relevant parties to establish a mechanism that when ready should be embedded in the policy (and that as any system can be improved and expanded over time). We also offer a small suggestion concerning the text on the timeline, in case it would provide more clarity. Looking forward to meeting some of you in Dublin at ICANN84, where perhaps we could also exchange on this subject. Kind Regards, Gemma on behalf of the GAC Small Team [cid:image001.gif@01DC4278.371AE350] GEMMA CAROLILLO Deputy Head of Unit Future Internet European Commission DG Communications Networks, Content and Technology Rue de la Loi, 51 1000 Brussels, Belgium gemma.carolillo@ec.europa.eu<mailto:gemma.carolillo@ec.europa.eu> From: Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Sent: Friday, October 3, 2025 10:54 PM To: irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Updated October 2025 ICANN org proposed language for IRT feedback prior to public comment period. Dear IRT Members, I want to sincerely thank you for your contributions and collaboration thus far. It has been a pleasure working with you over the past six months. As promised, attached are the clean and redline versions of the draft proposal language. Please provide your feedback no later than Friday, 17 October. Our goal is to subsequently publish this language for public comment on Wednesday, 22 October. Your feedback prior to the public comment period will be incorporated into an updated rationale paper, which will be published alongside the proposal during public comment as an additional resource for commenters, to show the discussions that have taken place in regard to the timeline for responding to urgent requests. As a reminder, the public comment period will provide a transparent opportunity for IRT members as well as other stakeholders to share feedback on the proposal. The public comment also provides the opportunity to raise alternative suggestions that have not already been discussed during the urgent request related IRT sessions. Clean Version of Proposed Language<https://urldefense.com/v3/__https:/docs.google.com/document/d/1Yao6h5gKbmBcX...> Redlined Version of Proposed Language.<https://urldefense.com/v3/__https:/docs.google.com/document/d/1EZpHwFWDM6lEg...> • Note that both versions do not include previous IRT feedback to make updates and ICANN org rationales easier to find. If you’d like to review previous IRT feedback, you can do so here<https://urldefense.com/v3/__https:/docs.google.com/document/d/1T2CMza4whggkv...> which also includes the previous (August 2025) Iteration of the proposed language.<https://urldefense.com/v3/__https:/docs.google.com/document/d/1T2CMza4whggkv...> Thank you again for your time, effort, and thoughtful contributions. I look forward to your feedback. Kind Regards, Isabelle Colas-Adeshina Sr. Manager, Policy Research & Stakeholder Programs Internet Corporation for Assigned Names and Numbers (ICANN) Los Angeles, CA www.icann.org<https://urldefense.com/v3/__http:/www.icann.org__;!!DOxrgLBm!DRrgcb1H4tJB9WP...> Mobile: +1 310 266 7469 _______________________________________________ IRT.RegDataPolicy mailing list -- irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> To unsubscribe send an email to irt.regdatapolicy-leave@icann.org<mailto:irt.regdatapolicy-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). 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