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,
Sarah Wyld, CIPP/E
Pronouns: she/they
Head, Policy & Privacy
Tucows #MakingTheInternetBetter
swyld@tucows.com
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