Hello All, I support Alan’s points. I do not support a mandated 30 day implementation window. A mandated 30 day window of implementation is not only a departure from standard operating procedure for implementation of a new Consensus Policy, but also introduces significant technical challenges and risk. As discussed previously, to make changes responsibly most operators will have to approach implementing their “new” data set in a phased approach. For example, first an RO might make fields optional, then in a second phase they would stop accepting certain fields, and finally they would simply not offer certain fields. This allows Rys and Rrs to make a large change in manageable phases reducing the risk of complications in any one phase. I believe this would also be complicated for ICANN compliance. If all parties are making changes at the same time it could be overwhelming. However, if there is a phased approach, operators and compliance can work together to find a way that supports Compliance’s needs as well as operators’. It’s also important to note that this agreement on 18 month implementation has been in place since discussions around the Temporary Specification and operators have already begun their planning around that timeline. Finally, it’s standard procedure to allow for implementation of a Consensus Policy up to and including the final implementation date to allow for exactly the flexibility described above. I’m happy to chat further on this and to arrange to have one of our tech folks join a call and chat as well. Many thanks, Beth From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> on behalf of Alan Woods via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Date: Monday, May 15, 2023 at 1:16 PM To: Dennis Chang <dennis.chang@icann.org> Cc: Dennis Chang via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] [Ext] RE: RegData IRT meeting agenda: 10 May 2023 CAUTION: This email came from outside your organization. Don’t trust emails, links, or attachments from senders that seem suspicious or you are not expecting. ________________________________ Dear Dennis, Catching up on the threads on this, I am happy to chime in on the email. The arrangements to be put in place for compliance with the Registration Data Policy are complex. Registry operators shall need to ensure that we have adequate time to not only develop, but test and implement/launch system updates to address the expected changes. We also must ensure we engage in clear and collaborative efforts with registrar partners to minimize, to the greatest extent possible, the impact of implementation to them and their operations. It would be our sincere hope that implementation expectations would remain as per usual, i.e. that the contracted parties may implement the policy at any time post the publication of the final policy, but no later than the last date for implementation. This will ensure and support a coordinated, phased and frankly a more stable implementation, for the benefit of all parties and the broader DNS. We also would like to remind that this path to implementation is required in the Interim Registration Data Policy. The current policy clearly notes that “During this stage, the contracted parties may implement either the Interim Policy or the Registration Data Policy in its entirety, or elements of both, as they prepare for the effective date of the Registration Data Policy document.” This was specifically inserted to provide flexibility to contracted parties, so as to ensure a measured and careful implementation period between publication of the policy and the final implementation date, acknowledging the likely complexity of this endeavor. Warmest regards, Alan Alan Woods Director, Compliance & Policy [Image removed by sender.] Donuts and Afilias have rebranded to Identity Digital. identity.digital<https://protect-us.mimecast.com/s/VSxFCM8xk1Sz5J3CwFSFs?domain=identity.digi...> NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Identity Digital Inc. . Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Please note my working hours may not be your working hours. Please do not feel obligated to respond to this e-mail outside of your normal working hours unless I have noted this is urgent. On Wed, May 10, 2023 at 8:27 PM Dennis Chang via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Hi Sarah, Good idea. It was a lot to digest. I will issue a IRT Task on the Timeline with details we’ve discussed. That way, we can collect all inputs on that email treads focused on the timeline. Thanks for supporting the meeting today. Dennis Chang From: Sarah Wyld <swyld@tucows.com<mailto:swyld@tucows.com>> Date: Wednesday, May 10, 2023 at 12:05 PM To: Dennis Chang <dennis.chang@icann.org<mailto:dennis.chang@icann.org>>, "Dennis Chang via IRT.RegDataPolicy" <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> Subject: [Ext] RE: [IRT.RegDataPolicy] RegData IRT meeting agenda: 10 May 2023 Hi Dennis & IPT Team, Re the implementation timing and effective date, which we discussed on today’s call, could you please explain the proposed process/timing here on the mailing list so that we can effectively review and consider? Thank you, -- Sarah Wyld, CIPP/E Policy & Privacy Manager Pronouns: she/they swyld@tucows.com<mailto:swyld@tucows.com> From: Dennis Chang via IRT.RegDataPolicy<mailto:irt.regdatapolicy@icann.org> Sent: April 28, 2023 3:23 PM To: Dennis Chang via IRT.RegDataPolicy<mailto:irt.regdatapolicy@icann.org> Subject: [IRT.RegDataPolicy] RegData IRT meeting agenda: 10 May 2023 Dear IRT, You should’ve all received an invitation from Andrea by now for 10 May 2023 IRT meeting. The agenda will include: 1. Implementation Timeline including policy effective date. 2. Registration Data Policy language update from public comment 3. Addendum to the Public Comment Report 4. RDAP Profile updates 5. Additional RDDS Information Policy (AWIP) 6. URS / UDRP updates We haven’t had meetings for a while and we’ve been doing a lot of work so that our IRT meeting are efficient and effective. While we are preparing for the IRT meeting and the documents, you may receive emails from google doc with notification of replies to your comments and resolution to those comments. There will be further communication about the upcoming meeting and IRT tasks being issued. We’ll keep you all in the loop as we make our progress towards the next milestone: Publication of the Registration Data Policy -- Kind Regards, Dennis S. Chang GDD Programs Director Phone: +1 213 293 7889 Sykpe: dennisSchang www.icann.org<https://protect-us.mimecast.com/s/Q0jDCQWBo7ho6RPFrH6m1?domain=icann.org> One World – One Internet _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto:IRT.RegDataPolicy@icann.org> https://mm.icann.org/mailman/listinfo/irt.regdatapolicy<https://protect-us.mimecast.com/s/AuAOCNkyl0FjN63I4xQ9n?domain=mm.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<https://protect-us.mimecast.com/s/s0Q7COYzm8CvAOxFkj5yl?domain=icann.org>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://protect-us.mimecast.com/s/ElewCPNAnQS346XIj6ew5?domain=icann.org>). 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