Follow up on IRT meeting discussion - recommendation 7
Team, I'm writing to follow up on the discussion we began toward the end of last Wednesday's IRT call on Recommendation #7, and specifically what the intention of that recommendation was. The EPDP Phase 1 Final Report makes it very clear that the registrant data elements (as well as the tech and name server data elements) enumerated in section 6.2 of the draft consensus policy are OPTIONAL for the registrar to transfer to the registry. The recommendation text makes reference to the data elements workbooks that were included in Annex D of the Final Report, which further clarify that the transfer of these data elements from the registrar to the registry is optional based on the policies, terms and conditions of the registry. During the call on Wednesday, there was some confusion about this topic and there was an assumption made by some that if these data elements are collected by the registrar, then they must be transferred to the registry - however, this is not what Recommendation #7 states or means. If the registry requires the data elements per its policies, terms or conditions, AND there is an appropriate legal basis and data processing agreement in place between the registry and its registrars, then (and only then) must the registrar transfer the data elements. However, if the registry does NOT require the data elements, then the registrar is NOT obligated to transfer those data elements to the registry. That is what the "optionality" under the "transfer logic" of the table in Recommendation #7 refers to. It's also worth noting that in the Scorecard that accompanied its resolution on the Phase 1 recommendations, the Board asks the EPDP to consider "whether the suggested corrections contained in the RySG's comments and the accompanying chart in Appendix G more accurately reflect the Phase 1 consensus". When the RySG developed those comments, we recognized that the recommendation text was potentially confusing, so we suggested a more clear way of presenting the recommendation. I'm including that at the bottom of this email so you can all review. I believe this more accurately reflects the expressed intention of Recommendation #7 and may be useful to ICANN staff in thinking about how to re-draft this part of the policy appropriately. Thanks, Marc RySG Chart: Data Elements Transferred from Registrar to Registry Domain Name REQUIRED to be transferred from Registrar to Registry Registrar Whois Server REQUIRED to be transferred from Registrar to Registry Registrar URL REQUIRED to be transferred from Registrar to Registry Updated Date REQUIRED to be transferred from Registrar to Registry Registrar Registration Expiration Date OPTIONAL to be transferred from Registrar to Registry Registrar REQUIRED to be transferred from Registrar to Registry Registrar IANA ID REQUIRED to be transferred from Registrar to Registry Registrar Abuse Contact Email REQUIRED to be transferred from Registrar to Registry Registrar Abuse Contact Phone REQUIRED to be transferred from Registrar to Registry Reseller OPTIONAL to be transferred based on Registry policies Domain Status(es) REQUIRED to be transferred from Registrar to Registry Registrant Fields * Name REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Organization OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Street REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * City REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * State/province REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Postal code REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Country REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Phone REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element * Phone ext OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Fax OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Fax ext OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Email Required to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element Tech Fields * Name OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Phone OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element * Email OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element Name Server OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided DNSSEC OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided Name Server IP Address OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided * Additional data elements as identified by Registry Operator in its registration policy, such as (i) status as Registry Operator Affiliate or Trademark Licensee [.MICROSOFT]; (ii) membership in community [.ECO]; (iii) licensing, registration or appropriate permits (.PHARMACY, .LAW] place of domicile [.NYC]; (iv) business entity or activity [.BANK, .BOT] REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require these data elements
Thanks for sending this, Marc. What you've described matches my understanding of the Report, and my memory of the work we did on those Workbooks to go through each data element and understand what was required of it. -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 7/15/2019 3:06 PM, Anderson, Marc via IRT.RegDataPolicy wrote:
Team,
I’m writing to follow up on the discussion we began toward the end of last Wednesday’s IRT call on Recommendation #7, and specifically what the intention of that recommendation was.
The EPDP Phase 1 Final Report makes it very clear that the registrant data elements (as well as the tech and name server data elements) enumerated in section 6.2 of the draft consensus policy are OPTIONAL for the registrar to transfer to the registry. The recommendation text makes reference to the data elements workbooks that were included in Annex D of the Final Report, which further clarify that the transfer of these data elements from the registrar to the registry is optional based on the policies, terms and conditions of the registry.
During the call on Wednesday, there was some confusion about this topic and there was an assumption made by some that if these data elements are collected by the registrar, then they must be transferred to the registry – however, this is not what Recommendation #7 states or means. If the registry requires the data elements per its policies, terms or conditions, AND there is an appropriate legal basis and data processing agreement in place between the registry and its registrars, then (and only then) must the registrar transfer the data elements. However, if the registry does NOT require the data elements, then the registrar is NOT obligated to transfer those data elements to the registry. That is what the “optionality” under the “transfer logic” of the table in Recommendation #7 refers to.
It’s also worth noting that in the Scorecard that accompanied its resolution on the Phase 1 recommendations, the Board asks the EPDP to consider “whether the suggested corrections contained in the RySG’s comments and the accompanying chart in Appendix G more accurately reflect the Phase 1 consensus”. When the RySG developed those comments, we recognized that the recommendation text was potentially confusing, so we suggested a more clear way of presenting the recommendation. I’m including that at the bottom of this email so you can all review. I believe this more accurately reflects the expressed intention of Recommendation #7 and may be useful to ICANN staff in thinking about how to re-draft this part of the policy appropriately.
Thanks,
Marc
RySG Chart:
*Data Elements Transferred from Registrar to Registry*
Domain Name
REQUIRED to be transferred from Registrar to Registry
Registrar Whois Server
REQUIRED to be transferred from Registrar to Registry
Registrar URL
REQUIRED to be transferred from Registrar to Registry
Updated Date
REQUIRED to be transferred from Registrar to Registry
Registrar Registration Expiration Date
OPTIONAL to be transferred from Registrar to Registry
Registrar
REQUIRED to be transferred from Registrar to Registry
Registrar IANA ID
REQUIRED to be transferred from Registrar to Registry
Registrar Abuse Contact Email
REQUIRED to be transferred from Registrar to Registry
Registrar Abuse Contact Phone
REQUIRED to be transferred from Registrar to Registry
Reseller
OPTIONAL to be transferred based on Registry policies
Domain Status(es)
REQUIRED to be transferred from Registrar to Registry
Registrant Fields
· Name
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Organization
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Street
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· City
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· State/province
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Postal code
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Country
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Phone
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Phone ext
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Fax
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Fax ext
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
Required to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
Tech Fields
· Name
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Phone
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
Name Server
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided
DNSSEC
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided
Name Server IP Address
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided
· Additional data elements as identified by Registry Operator in its registration policy, such as (i) status as Registry Operator Affiliate or Trademark Licensee [.MICROSOFT]; (ii) membership in community [.ECO]; (iii) licensing, registration or appropriate permits (.PHARMACY, .LAW] place of domicile [.NYC]; (iv) business entity or activity [.BANK, .BOT]
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require these data elements
_______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org https://mm.icann.org/mailman/listinfo/irt.regdatapolicy
_______________________________________________ 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) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Thanks Marc, this clarification is great and confirms my read on the recommendation. Best, Theo Geurts CIPP/E Privacy & GRC Officer | Realtime Register B.V. Ceintuurbaan 32A 8024 AA - ZWOLLE - The Netherlands T: +31.384530759 F: +31.384524734 U: www.realtimeregister.com E: legal@realtimeregister.com On 15-7-2019 21:06, Anderson, Marc via IRT.RegDataPolicy wrote:
Team,
I’m writing to follow up on the discussion we began toward the end of last Wednesday’s IRT call on Recommendation #7, and specifically what the intention of that recommendation was.
The EPDP Phase 1 Final Report makes it very clear that the registrant data elements (as well as the tech and name server data elements) enumerated in section 6.2 of the draft consensus policy are OPTIONAL for the registrar to transfer to the registry. The recommendation text makes reference to the data elements workbooks that were included in Annex D of the Final Report, which further clarify that the transfer of these data elements from the registrar to the registry is optional based on the policies, terms and conditions of the registry.
During the call on Wednesday, there was some confusion about this topic and there was an assumption made by some that if these data elements are collected by the registrar, then they must be transferred to the registry – however, this is not what Recommendation #7 states or means. If the registry requires the data elements per its policies, terms or conditions, AND there is an appropriate legal basis and data processing agreement in place between the registry and its registrars, then (and only then) must the registrar transfer the data elements. However, if the registry does NOT require the data elements, then the registrar is NOT obligated to transfer those data elements to the registry. That is what the “optionality” under the “transfer logic” of the table in Recommendation #7 refers to.
It’s also worth noting that in the Scorecard that accompanied its resolution on the Phase 1 recommendations, the Board asks the EPDP to consider “whether the suggested corrections contained in the RySG’s comments and the accompanying chart in Appendix G more accurately reflect the Phase 1 consensus”. When the RySG developed those comments, we recognized that the recommendation text was potentially confusing, so we suggested a more clear way of presenting the recommendation. I’m including that at the bottom of this email so you can all review. I believe this more accurately reflects the expressed intention of Recommendation #7 and may be useful to ICANN staff in thinking about how to re-draft this part of the policy appropriately.
Thanks,
Marc
RySG Chart:
*Data Elements Transferred from Registrar to Registry*
Domain Name
REQUIRED to be transferred from Registrar to Registry
Registrar Whois Server
REQUIRED to be transferred from Registrar to Registry
Registrar URL
REQUIRED to be transferred from Registrar to Registry
Updated Date
REQUIRED to be transferred from Registrar to Registry
Registrar Registration Expiration Date
OPTIONAL to be transferred from Registrar to Registry
Registrar
REQUIRED to be transferred from Registrar to Registry
Registrar IANA ID
REQUIRED to be transferred from Registrar to Registry
Registrar Abuse Contact Email
REQUIRED to be transferred from Registrar to Registry
Registrar Abuse Contact Phone
REQUIRED to be transferred from Registrar to Registry
Reseller
OPTIONAL to be transferred based on Registry policies
Domain Status(es)
REQUIRED to be transferred from Registrar to Registry
Registrant Fields
· Name
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
·Organization
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Street
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· City
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
·State/province
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Postal code
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Country
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Phone
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
· Phone ext
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Fax
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Fax ext
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
Required to be transferred from Registrar to Registry IF Registry terms/conditions/policies require this data element
Tech Fields
· Name
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
· Phone
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided and IF Registry terms/conditions/policies require this data element
Name Server
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided
DNSSEC
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided
Name Server IP Address
OPTIONAL for RNH to provide, REQUIRED to be transferred from Registrar to Registry IF provided
· Additional data elements as identified by Registry Operator in its registration policy, such as (i) status as Registry Operator Affiliate or Trademark Licensee [.MICROSOFT]; (ii) membership in community [.ECO]; (iii) licensing, registration or appropriate permits (.PHARMACY, .LAW] place of domicile [.NYC]; (iv) business entity or activity [.BANK, .BOT]
REQUIRED to be transferred from Registrar to Registry IF Registry terms/conditions/policies require these data elements
_______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org https://mm.icann.org/mailman/listinfo/irt.regdatapolicy
_______________________________________________ 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) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
participants (3)
-
Anderson, Marc -
Sarah Wyld -
theo geurts