Hi Dennis and team, The RrSG has begun a deep dive into the Registration Data Policy, and that prompted a couple questions. 1. Is there any update or ETA on the publication for this Policy? We are very excited! 2. Looking at the 13 November 2023 version, we notice the definition in 3.7 includes both "Reasonable Requests for Lawful Disclosure” and “Urgent Requests for Lawful Disclosure”. Should the Urgent definition be removed from 3.7? Thank you, *Sarah Wyld, CIPP/E* Policy & Privacy Manager Pronouns: she/they swyld@tucows.com On 2023-11-15 8:16 p.m., Dennis Chang via IRT.RegDataPolicy wrote:
Dear IRT,
Thank you for the excellent support at the ICANN78 for Registration Data Policy. I was glad to see both RrSG and RySG sessions included Registration Data Policy implementation on the agenda and the proactive education and call to action happening prior to the publication of the policy.
The ICANN78 IRT session <https://icann78.sched.com/event/1T4Mj/gnso-registration-data-policy-irt>was very productive and served as a critical meeting getting us aligned in providing all of our support to the new approach to the policy publication. I am speaking, of course, of the publication excluding Urgent Requests. This, as I am reminded, was an approach we had discussed a long ago but became an approach of choice with the GAC’s letter to the Board. We all know just how difficult it was for us to come up with the policy language requirement balancing the need for timely disclosure with the practical business realities at hand.
With the IRT support, you’ve seen that Seb wrote his letter to the GNSO Council documenting the IRT’s agreement and asking the GNSO Council to take up the Urgent Request issue. We were well supported at the IRT session by Becky’s attendance to clarify the Board’s understanding of the difficult issue and the thinking that publication should proceed without the sections pertaining to Urgent Requests.
At the moment, ICANN org is coordinating with the Board to receive formal direction to proceed with publication of the policy. Once that direction is received, we’d be able to fill in the effective dates in Section 4 of the policy. As promised, we will maintain the full 18-month implementation period with the 6+12 concept we had agreed to. I am providing a copy of the policy with tbd dates <https://community.icann.org/display/RDPIRT/RegDataPolicy+Implementation+Resource+Documents?preview=/124847947/280297769/Registration%20Data%20Policy%20-%20Updated%2013%20November%202023.pdf>for now so that you can clearly see the changes reflecting the removal of the Urgent Request definition and response time requirement. One more thing - you’ll note an addition in Section 9.2.4 where we are adding a reference to 9.2.2.4. This is meant to correct a reference that had been left off inadvertently.
Our next step will be to inform the IRT when we have direction from the Board and dates and come back to you with the final clean policy document ready for publication.
I’d like to take this time to announce that Thomas Rickert has replaced Sebestian Ducos as our GNSO Liaison going forward. Please join me in thanking Seb for his fantastic support throughout and until the last minute writing that important email to the GNSO Council <https://mm.icann.org/pipermail/irt.regdatapolicy/2023-October/001058.html>for us. You might be interested to know that Seb thought it was finally the right time and the two of us conducted a jumping high-five after our meeting.
I do think it’s about time we enjoy a milestone victory after all these years. As always, thank you so much for hanging in there and supporting this policy implementation until the end.
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Gratefully yours,
Dennis S. Chang
GDD Programs Director
Phone: +1 213 293 7889
Sykpe: dennisSchang
www.icann.org <http://www.icann.org> One World – One Internet
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