Hello team,

Thank you for a thoughtful and productive call today. I want to take a moment to recap my input and address some of what we discussed.


1. Urgent requests are already being handled. 

We should understand what problems or gaps exist in the current process to ensure that these are addressed by our implementation of this Policy recommendation. Can someone on the requestor side provide more information on that?


2. We must consider the practical aspects of the implementation. 

There is a requirement in the Registration Data Policy that the Registrar and Registry Operator must publish the mechanism and process for submitting Disclosure Requests. If Urgent requests are to be properly triaged they would need to go through a separate path, and that separate path must not be public or it will be misused. 

Perhaps we should consider having ICANN maintain two lists: one of authenticated LEA requestors (with jurisdiction), and one of registrar contact points (with jurisdiction); in Urgent cases the authenticated LEA person would be able to access the registrar's emergency disclosure point of contact.


3. Scope of the IRT

Isabelle raised a reasonable question of scope; we've been asked to work on the timeline, and the method for submitting requests is a separate thing although (as we agreed on the call) they are related. We all share the goal of implementing the EPDP Phase 1 Rec 18 in a functional and useful manner, so to ignore the request submission process would not achieve this goal. As long as we do work on a timeline I don't think we are prevented from working on other related topics.


Thank you,


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Sarah Wyld, CIPP/E
Pronouns: she/they

Head, Policy & Privacy
Tucows #MakingTheInternetBetter

swyld@tucows.com

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