Draft language - Section 10 + Urgent requests
Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here <https://docs.google.com/document/d/1HP8kXyd8Ti5rXwAbJQBe6Rq4Pb9Lju0sPRbytej2...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. Thank you, -- *Sarah Wyld, CIPP/E* Pronouns: she/they Head, Policy & Privacy Tucows #MakingTheInternetBetter swyld@tucows.com /Responses to this email are processed according to the Tucows Privacy Policy <https://www.tucows.com/privacy>/
Thank you, Sarah and RrSG, We appreciate your efforts and sharing your proposed language following our discussion during ICANN 83. I encourage this group to please review the language and provide your thoughts and feedback via the shared Google document or on list. We will also review the language and follow up shortly. 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<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: Friday, June 27, 2025 at 12:38 PM To: "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/1HP8kXyd8Ti5rX...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. 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 [tucows.com]<https://urldefense.com/v3/__https:/www.tucows.com/privacy__;!!PtGJab4!7Fipo9...>
Hello All, Just a note that the RySG is currently considering and will weigh in this week re: Urgent Requests. We had several team members at conferences following Prague, so we apologize for the delay. Many thanks, Beth From: Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Friday, June 27, 2025 at 3:36 PM To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here<https://docs.google.com/document/d/1HP8kXyd8Ti5rXwAbJQBe6Rq4Pb9Lju0sPRbytej2...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. 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>
Hello All, The RySG appreciates the RrSG’s proposal regarding changes to the Urgent Request Section language proposed by ICANN, however, Registries believe that the original ICANN language, with minimal changes, is a more straightforward approach that can also address RR concerns. We believe that the edited language below, combined with the shared agreement among the IRT that any actions under this language are based solely on the establishment of a mutually agreed authentication system for law enforcement, negates the need to add the additional procedural language. For more context, this also assumes that the authentication system (the System) currently being developed by the IRT/PSWG Small Group will: 1-Be specific to use by law enforcement and that law enforcement will be defined as part of the System; 2-The Terms and Conditions of an authenticated law enforcement user of the System will include requirements for said user to have done their due diligence to ensure the request received is in fact “urgent” and lawful. If the requests Contracted Parties receive have been subject to this rigor, we don’t think that the more specific additional language is required. In addition, we believe that requests meeting this level of rigor would not require more than 24 hours to respond. Looking forward to discussion during our next meeting. Please find the redline attached. Thank you, RySG From: Elizabeth Bacon <bbacon@pir.org> Date: Monday, July 14, 2025 at 10:15 AM To: Sarah Wyld <swyld@tucows.com>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello All, Just a note that the RySG is currently considering and will weigh in this week re: Urgent Requests. We had several team members at conferences following Prague, so we apologize for the delay. Many thanks, Beth From: Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Friday, June 27, 2025 at 3:36 PM To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here<https://docs.google.com/document/d/1HP8kXyd8Ti5rXwAbJQBe6Rq4Pb9Lju0sPRbytej2...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. 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>
Dear RySG, Thank you for taking the time to propose alternative urgent request language. I have also included your proposal in the IRT drive and created a google document for ease of feedback/commenting. I also ask the IRT to consider the RySGs proposal and provide feedback no later than end of day Monday, 28 July. We are continuing to work on our proposal and will consider the RySG’s input as well. Thank you again. 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<http://www.icann.org> Mobile: +1 310 266 7469 From: "Elizabeth Bacon via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org> Reply-To: Elizabeth Bacon <bbacon@pir.org> Date: Friday, July 18, 2025 at 9:07 AM To: Sarah Wyld <swyld@tucows.com>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Draft language - Section 10 + Urgent requests Hello All, The RySG appreciates the RrSG’s proposal regarding changes to the Urgent Request Section language proposed by ICANN, however, Registries believe that the original ICANN language, with minimal changes, is a more straightforward approach that can also address RR concerns. We believe that the edited language below, combined with the shared agreement among the IRT that any actions under this language are based solely on the establishment of a mutually agreed authentication system for law enforcement, negates the need to add the additional procedural language. For more context, this also assumes that the authentication system (the System) currently being developed by the IRT/PSWG Small Group will: 1-Be specific to use by law enforcement and that law enforcement will be defined as part of the System; 2-The Terms and Conditions of an authenticated law enforcement user of the System will include requirements for said user to have done their due diligence to ensure the request received is in fact “urgent” and lawful. If the requests Contracted Parties receive have been subject to this rigor, we don’t think that the more specific additional language is required. In addition, we believe that requests meeting this level of rigor would not require more than 24 hours to respond. Looking forward to discussion during our next meeting. Please find the redline attached. Thank you, RySG From: Elizabeth Bacon <bbacon@pir.org> Date: Monday, July 14, 2025 at 10:15 AM To: Sarah Wyld <swyld@tucows.com>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello All, Just a note that the RySG is currently considering and will weigh in this week re: Urgent Requests. We had several team members at conferences following Prague, so we apologize for the delay. Many thanks, Beth From: Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Friday, June 27, 2025 at 3:36 PM To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/1HP8kXyd8Ti5rX...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. 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 [tucows.com]<https://urldefense.com/v3/__https:/www.tucows.com/privacy__;!!PtGJab4!6mhE9V...>
Hi All, Apologies, I realized I did not include the google link for the RySG proposal. Please see the link below. RySG Urgent Request Proposal<https://docs.google.com/document/d/1LeWpjBQfWrxRmn5UaG4Con_HKnFAcpvxUPnM2vII...> Thank you! -- 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: "Elizabeth Bacon via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org> Reply-To: Elizabeth Bacon <bbacon@pir.org> Date: Friday, July 18, 2025 at 9:07 AM To: Sarah Wyld <swyld@tucows.com>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Draft language - Section 10 + Urgent requests Hello All, The RySG appreciates the RrSG’s proposal regarding changes to the Urgent Request Section language proposed by ICANN, however, Registries believe that the original ICANN language, with minimal changes, is a more straightforward approach that can also address RR concerns. We believe that the edited language below, combined with the shared agreement among the IRT that any actions under this language are based solely on the establishment of a mutually agreed authentication system for law enforcement, negates the need to add the additional procedural language. For more context, this also assumes that the authentication system (the System) currently being developed by the IRT/PSWG Small Group will: 1-Be specific to use by law enforcement and that law enforcement will be defined as part of the System; 2-The Terms and Conditions of an authenticated law enforcement user of the System will include requirements for said user to have done their due diligence to ensure the request received is in fact “urgent” and lawful. If the requests Contracted Parties receive have been subject to this rigor, we don’t think that the more specific additional language is required. In addition, we believe that requests meeting this level of rigor would not require more than 24 hours to respond. Looking forward to discussion during our next meeting. Please find the redline attached. Thank you, RySG From: Elizabeth Bacon <bbacon@pir.org> Date: Monday, July 14, 2025 at 10:15 AM To: Sarah Wyld <swyld@tucows.com>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello All, Just a note that the RySG is currently considering and will weigh in this week re: Urgent Requests. We had several team members at conferences following Prague, so we apologize for the delay. Many thanks, Beth From: Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Friday, June 27, 2025 at 3:36 PM To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/1HP8kXyd8Ti5rX...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. 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 [tucows.com]<https://urldefense.com/v3/__https:/www.tucows.com/privacy__;!!PtGJab4!6mhE9V...>
Thank you, Isabelle! From: Isabelle Colas-Adeshina via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Friday, July 18, 2025 at 12:31 PM To: Elizabeth Bacon <bbacon@pir.org>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Draft language - Section 10 + Urgent requests Hi All, Apologies, I realized I did not include the google link for the RySG proposal. Please see the link below. RySG Urgent Request Proposal<https://docs.google.com/document/d/1LeWpjBQfWrxRmn5UaG4Con_HKnFAcpvxUPnM2vII...> Thank you! -- 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: "Elizabeth Bacon via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org> Reply-To: Elizabeth Bacon <bbacon@pir.org> Date: Friday, July 18, 2025 at 9:07 AM To: Sarah Wyld <swyld@tucows.com>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Re: Draft language - Section 10 + Urgent requests Hello All, The RySG appreciates the RrSG’s proposal regarding changes to the Urgent Request Section language proposed by ICANN, however, Registries believe that the original ICANN language, with minimal changes, is a more straightforward approach that can also address RR concerns. We believe that the edited language below, combined with the shared agreement among the IRT that any actions under this language are based solely on the establishment of a mutually agreed authentication system for law enforcement, negates the need to add the additional procedural language. For more context, this also assumes that the authentication system (the System) currently being developed by the IRT/PSWG Small Group will: 1-Be specific to use by law enforcement and that law enforcement will be defined as part of the System; 2-The Terms and Conditions of an authenticated law enforcement user of the System will include requirements for said user to have done their due diligence to ensure the request received is in fact “urgent” and lawful. If the requests Contracted Parties receive have been subject to this rigor, we don’t think that the more specific additional language is required. In addition, we believe that requests meeting this level of rigor would not require more than 24 hours to respond. Looking forward to discussion during our next meeting. Please find the redline attached. Thank you, RySG From: Elizabeth Bacon <bbacon@pir.org> Date: Monday, July 14, 2025 at 10:15 AM To: Sarah Wyld <swyld@tucows.com>, irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello All, Just a note that the RySG is currently considering and will weigh in this week re: Urgent Requests. We had several team members at conferences following Prague, so we apologize for the delay. Many thanks, Beth From: Sarah Wyld via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Friday, June 27, 2025 at 3:36 PM To: irt.regdatapolicy@icann.org <irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] Draft language - Section 10 + Urgent requests Hello IRT Team, The RrSG has drafted language for this group's consideration, incorporating specific timing for responding to Urgent disclosure requests into the existing text of §10 of the Registration Data Policy. I have attached a PDF of the suggested language, and you can also find a Google Doc copy here [docs.google.com]<https://urldefense.com/v3/__https:/docs.google.com/document/d/1HP8kXyd8Ti5rX...> (which may be more useful as the tracked changes are more readily visible and there is a clarifying comment). I hope that this is a helpful step forward in our discussion. 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 [tucows.com]<https://urldefense.com/v3/__https:/www.tucows.com/privacy__;!!PtGJab4!6mhE9V...>
participants (3)
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Elizabeth Bacon -
Isabelle Colas-Adeshina -
Sarah Wyld