Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH... Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org>
Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that *updates, if needed, are made to the contractual requirements* concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other *existing *ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote:
Dear IRT,
The recommendations 9 is open for IRT review and added to the IRT Task List as:
19
_Review Recommendation 9 Analysis: Ry&Rr to ICANN org <https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit>_
20190630
The review document with the proposed policy language has been added to the IRT Team Drive.
The task assignment is linked to it for your future reference.
https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...
Thank you for your continuing support.
—
Kind Regards,
Dennis S. Chang
GDD Services & Engagement Program Director
Telephone: +1 213 293 7889
Skype: dennisSchang
www.icann.org <http://www.icann.org>
_______________________________________________ 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.
Team, I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance). The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation. Best, Marc From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote: Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH... Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org> _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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.
Hi, Makes sense to me. Thanks. Amr
On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Team,
I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance).
The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation.
Best,
Marc
From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hello Team,
I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech.
This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc.
But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)."
Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas.
Thanks,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 6/20/2019 3:33 AM, Dennis Chang wrote:
Dear IRT,
The recommendations 9 is open for IRT review and added to the IRT Task List as:
19
[Review Recommendation 9 Analysis: Ry&Rr to ICANN org](https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...)
20190630
The review document with the proposed policy language has been added to the IRT Team Drive.
The task assignment is linked to it for your future reference.
https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...
Thank you for your continuing support.
—
Kind Regards,
Dennis S. Chang
GDD Services & Engagement Program Director
Telephone: +1 213 293 7889
Skype: dennisSchang
[www.icann.org](http://www.icann.org/)
_______________________________________________
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.
I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time? Sincerely, Diane On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja<mailto:aelsadr@icannpolicy.ninja>> wrote: Hi, Makes sense to me. Thanks. Amr On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Team, I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance). The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation. Best, Marc From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org<mailto:irt.regdatapolicy-bounces@icann.org>> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote: Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org/> _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto:IRT.RegDataPolicy@icann.org> https://mm.icann.org/mailman/listinfo/irt.regdatapolicy<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<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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.
Hi, To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made. The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point. Of course, if I have missed anything, would be happy to be corrected. Thanks. Amr
On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com> wrote:
I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time?
Sincerely,
Diane
On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja> wrote:
Hi,
Makes sense to me.
Thanks.
Amr
On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Team,
I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance).
The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation.
Best,
Marc
From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hello Team,
I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech.
This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc.
But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)."
Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas.
Thanks,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 6/20/2019 3:33 AM, Dennis Chang wrote:
Dear IRT,
The recommendations 9 is open for IRT review and added to the IRT Task List as:
19
[Review Recommendation 9 Analysis: Ry&Rr to ICANN org](https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...)
20190630
The review document with the proposed policy language has been added to the IRT Team Drive.
The task assignment is linked to it for your future reference.
https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...
Thank you for your continuing support.
—
Kind Regards,
Dennis S. Chang
GDD Services & Engagement Program Director
Telephone: +1 213 293 7889
Skype: dennisSchang
[www.icann.org](http://www.icann.org/)
_______________________________________________
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.
_______________________________________________ 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.
Dear Amr- Thank you for this clarification. I understand and agree. Diane Plaut General Counsel and Privacy Officer [cid:image001.png@01D3CA70.18FC1D40] Direct +1 646-899-2806 diane.plaut@corsearch.com<mailto:diane.plaut@corsearch.com> 220 West 42nd Street, 11th Floor, New York, NY 10036, United States www.corsearch.com<http://www.corsearch.com/> Join Corsearch on Twitter<https://twitter.com/corsearch> Linkedin<https://www.linkedin.com/company/2593860/> Trademarks + Brands<http://trademarksandbrands.corsearch.com/> Customer Service/Platform Support: 1 800 SEARCH1™ (1 800 732 7241) Corsearch.USCustomerService@corsearch.com<mailto:Corsearch.USCustomerService@corsearch.com> Confidentiality Notice: This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession. From: Amr Elsadr <aelsadr@icannpolicy.ninja> Reply-To: Amr Elsadr <aelsadr@icannpolicy.ninja> Date: Monday, June 24, 2019 at 6:33 AM To: "Plaut, Diane" <Diane.Plaut@corsearch.com> Cc: "mcanderson@verisign.com" <mcanderson@verisign.com>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hi, To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made. The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point. Of course, if I have missed anything, would be happy to be corrected. Thanks. Amr On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time? Sincerely, Diane On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja<mailto:aelsadr@icannpolicy.ninja>> wrote: Hi, Makes sense to me. Thanks. Amr On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Team, I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance). The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation. Best, Marc From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org<mailto:irt.regdatapolicy-bounces@icann.org>> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote: Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org/> _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto:IRT.RegDataPolicy@icann.org> https://mm.icann.org/mailman/listinfo/irt.regdatapolicy<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<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto:IRT.RegDataPolicy@icann.org> https://mm.icann.org/mailman/listinfo/irt.regdatapolicy<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<https://www.icann.org/privacy/policy>) and the website Terms of Service (https://www.icann.org/privacy/tos<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.
Thank YOU, Diane. Amr Sent from Mobile On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane <Diane.Plaut@corsearch.com> wrote:
Dear Amr-
Thank you for this clarification. I understand and agree.
Diane Plaut
General Counsel and Privacy Officer
[cid:image001.png@01D3CA70.18FC1D40]
Direct +1 646-899-2806 diane.plaut@corsearch.com
220 West 42nd Street, 11th Floor, New York, NY 10036, United States [www.corsearch.com](http://www.corsearch.com/)
Join Corsearch on [Twitter](https://twitter.com/corsearch) [Linkedin](https://www.linkedin.com/company/2593860/) [Trademarks + Brands](http://trademarksandbrands.corsearch.com/)
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Confidentiality Notice: This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession.
From: Amr Elsadr <aelsadr@icannpolicy.ninja> Reply-To: Amr Elsadr <aelsadr@icannpolicy.ninja> Date: Monday, June 24, 2019 at 6:33 AM To: "Plaut, Diane" <Diane.Plaut@corsearch.com> Cc: "mcanderson@verisign.com" <mcanderson@verisign.com>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hi,
To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made.
The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point.
Of course, if I have missed anything, would be happy to be corrected.
Thanks.
Amr
On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com> wrote:
I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time?
Sincerely,
Diane
On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja> wrote:
Hi,
Makes sense to me.
Thanks.
Amr
On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Team,
I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance).
The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation.
Best,
Marc
From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hello Team,
I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech.
This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc.
But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)."
Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas.
Thanks,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 6/20/2019 3:33 AM, Dennis Chang wrote:
Dear IRT,
The recommendations 9 is open for IRT review and added to the IRT Task List as:
19
[Review Recommendation 9 Analysis: Ry&Rr to ICANN org](https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...)
20190630
The review document with the proposed policy language has been added to the IRT Team Drive.
The task assignment is linked to it for your future reference.
https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...
Thank you for your continuing support.
—
Kind Regards,
Dennis S. Chang
GDD Services & Engagement Program Director
Telephone: +1 213 293 7889
Skype: dennisSchang
[www.icann.org](http://www.icann.org/)
_______________________________________________
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IRT.RegDataPolicy@icann.org
https://mm.icann.org/mailman/listinfo/irt.regdatapolicy
_______________________________________________
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_______________________________________________ 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 to the whole team for this useful discussion about Rec 9. Dennis/Staff - can Rec 9 be on the agenda for our upcoming meeting, please? At this time, the draft policy does not matche my understanding of the intent of this recommendation, and I think we need to to discuss as a team before we can effectively make edits in the google doc. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/24/2019 8:15 PM, Amr Elsadr wrote:
Thank YOU, Diane.
Amr
Sent from Mobile
On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane <Diane.Plaut@corsearch.com <mailto:Diane.Plaut@corsearch.com>> wrote:
Dear Amr-
Thank you for this clarification. I understand and agree.
*Diane Plaut*
General Counsel and Privacy Officer
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Direct +1 646-899-2806 diane.plaut@corsearch.com <mailto:diane.plaut@corsearch.com>
220 West 42^nd Street, 11^th Floor, New York, NY 10036, United States www.corsearch.com <http://www.corsearch.com/>
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*Confidentiality Notice:* This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession.
*From: *Amr Elsadr <aelsadr@icannpolicy.ninja> *Reply-To: *Amr Elsadr <aelsadr@icannpolicy.ninja> *Date: *Monday, June 24, 2019 at 6:33 AM *To: *"Plaut, Diane" <Diane.Plaut@corsearch.com> *Cc: *"mcanderson@verisign.com" <mcanderson@verisign.com>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> *Subject: *Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hi,
To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made.
The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point.
Of course, if I have missed anything, would be happy to be corrected.
Thanks.
Amr
On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com <mailto:Diane.Plaut@corsearch.com>> wrote:
I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time?
Sincerely,
Diane
On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja <mailto:aelsadr@icannpolicy.ninja>> wrote:
Hi,
Makes sense to me.
Thanks.
Amr
On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org <mailto:irt.regdatapolicy@icann.org>> wrote:
Team,
I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance).
The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation.
Best,
Marc
*From:* IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org <mailto:irt.regdatapolicy-bounces@icann.org>> *On Behalf Of *Sarah Wyld *Sent:* Friday, June 21, 2019 8:26 AM *To:* irt.regdatapolicy@icann.org <mailto:irt.regdatapolicy@icann.org> *Subject:* [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hello Team,
I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech.
This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc.
But the Rec itself starts with "The EPDP Team recommends that *updates, if needed, are made to the contractual requirements* concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)."
Does this mean that, instead of creating a new policy section about it, we actually need to go back to other *existing *ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas.
Thanks,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 6/20/2019 3:33 AM, Dennis Chang wrote:
Dear IRT,
The recommendations 9 is open for IRT review and added to the IRT Task List as:
19
_Review Recommendation 9 Analysis: Ry&Rr to ICANN org <https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit>_
20190630
The review document with the proposed policy language has been added to the IRT Team Drive.
The task assignment is linked to it for your future reference.
https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...
Thank you for your continuing support.
—
Kind Regards,
Dennis S. Chang
GDD Services & Engagement Program Director
Telephone: +1 213 293 7889
Skype: dennisSchang
www.icann.org <http://www.icann.org/>
_______________________________________________
IRT.RegDataPolicy mailing list
IRT.RegDataPolicy@icann.org <mailto: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.
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_______________________________________________ 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.
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Hi Sarah, Yes, Rec 9 is on the agenda for the IRT meeting next week. We plan to complete Rec 5 discussion and continue down 6, 7, 8, and 9. The agenda for the IRT meetings can be found on the IRT wiki. https://community.icann.org/display/RDPIRT/2019-07-10+Registration+Data+Poli... Please feel free to propose agenda items at any time. Reminder for all IRT. Our next meeting is scheduled for 90 minutes on 10 July and you should have received the invitation from Andrea. Thanks Dennis Chang From: "IRT.RegDataPolicy" <irt.regdatapolicy-bounces@icann.org> on behalf of Sarah Wyld <swyld@tucows.com> Organization: Tucows Date: Friday, July 5, 2019 at 6:35 AM To: "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Thanks to the whole team for this useful discussion about Rec 9. Dennis/Staff - can Rec 9 be on the agenda for our upcoming meeting, please? At this time, the draft policy does not matche my understanding of the intent of this recommendation, and I think we need to to discuss as a team before we can effectively make edits in the google doc. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/24/2019 8:15 PM, Amr Elsadr wrote: Thank YOU, Diane. Amr Sent from Mobile On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: Dear Amr- Thank you for this clarification. I understand and agree. Diane Plaut General Counsel and Privacy Officer [/var/folders/lm/gc2l6l5j1hzc406w83m5v4p0fjxh_c/T/com.microsoft.Outlook/Content.MSO/C6F6FA6C.tmp] Direct +1 646-899-2806 diane.plaut@corsearch.com<mailto:diane.plaut@corsearch.com> 220 West 42nd Street, 11th Floor, New York, NY 10036, United States www.corsearch.com<http://www.corsearch.com/> Join Corsearch on Twitter<https://twitter.com/corsearch> Linkedin<https://www.linkedin.com/company/2593860/> Trademarks + Brands<http://trademarksandbrands.corsearch.com/> Customer Service/Platform Support: 1 800 SEARCH1™ (1 800 732 7241) Corsearch.USCustomerService@corsearch.com<mailto:Corsearch.USCustomerService@corsearch.com> Confidentiality Notice: This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession. From: Amr Elsadr <aelsadr@icannpolicy.ninja><mailto:aelsadr@icannpolicy.ninja> Reply-To: Amr Elsadr <aelsadr@icannpolicy.ninja><mailto:aelsadr@icannpolicy.ninja> Date: Monday, June 24, 2019 at 6:33 AM To: "Plaut, Diane" <Diane.Plaut@corsearch.com><mailto:Diane.Plaut@corsearch.com> Cc: "mcanderson@verisign.com"<mailto:mcanderson@verisign.com> <mcanderson@verisign.com><mailto:mcanderson@verisign.com>, "irt.regdatapolicy@icann.org"<mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hi, To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made. The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point. Of course, if I have missed anything, would be happy to be corrected. Thanks. Amr On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time? Sincerely, Diane On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja<mailto:aelsadr@icannpolicy.ninja>> wrote: Hi, Makes sense to me. Thanks. Amr On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Team, I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance). The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation. Best, Marc From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org<mailto:irt.regdatapolicy-bounces@icann.org>> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote: Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH... Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org/> _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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.
Hello Dennis, Thank you for the update. The CPH members of the IRT are satisfied with this new approach. We do have one question: could you please clarify what the Scope change was, which relates to this Rec 9 approach? I reviewed and even tried looking through the document history but I couldn't figure out what the relevant change was. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 7/5/2019 10:54 AM, Dennis Chang wrote:
Hi Sarah,
Yes, Rec 9 is on the agenda for the IRT meeting next week.
We plan to complete Rec 5 discussion and continue down 6, 7, 8, and 9.
The agenda for the IRT meetings can be found on the IRT wiki.
https://community.icann.org/display/RDPIRT/2019-07-10+Registration+Data+Poli...
Please feel free to propose agenda items at any time.
Reminder for all IRT.
Our next meeting is scheduled for 90 minutes on 10 July and you should have received the invitation from Andrea.
Thanks
Dennis Chang
*From: *"IRT.RegDataPolicy" <irt.regdatapolicy-bounces@icann.org> on behalf of Sarah Wyld <swyld@tucows.com> *Organization: *Tucows *Date: *Friday, July 5, 2019 at 6:35 AM *To: *"irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> *Subject: *Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Thanks to the whole team for this useful discussion about Rec 9.
Dennis/Staff - can Rec 9 be on the agenda for our upcoming meeting, please? At this time, the draft policy does not matche my understanding of the intent of this recommendation, and I think we need to to discuss as a team before we can effectively make edits in the google doc.
Thanks,
-- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392
On 6/24/2019 8:15 PM, Amr Elsadr wrote:
Thank YOU, Diane.
Amr
Sent from Mobile
On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane <Diane.Plaut@corsearch.com <mailto:Diane.Plaut@corsearch.com>> wrote:
Dear Amr-
Thank you for this clarification. I understand and agree.
*Diane Plaut*
General Counsel and Privacy Officer
/var/folders/lm/gc2l6l5j1hzc406w83m5v4p0fjxh_c/T/com.microsoft.Outlook/Content.MSO/C6F6FA6C.tmp
Direct +1 646-899-2806 diane.plaut@corsearch.com <mailto:diane.plaut@corsearch.com>
220 West 42^nd Street, 11^th Floor, New York, NY 10036, United States www.corsearch.com <http://www.corsearch.com/>
Join Corsearch on Twitter <https://twitter.com/corsearch> Linkedin <https://www.linkedin.com/company/2593860/> Trademarks + Brands <http://trademarksandbrands.corsearch.com/>
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*Confidentiality Notice:* This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession.
*From: *Amr Elsadr <aelsadr@icannpolicy.ninja> <mailto:aelsadr@icannpolicy.ninja> *Reply-To: *Amr Elsadr <aelsadr@icannpolicy.ninja> <mailto:aelsadr@icannpolicy.ninja> *Date: *Monday, June 24, 2019 at 6:33 AM *To: *"Plaut, Diane" <Diane.Plaut@corsearch.com> <mailto:Diane.Plaut@corsearch.com> *Cc: *"mcanderson@verisign.com" <mailto:mcanderson@verisign.com> <mcanderson@verisign.com> <mailto:mcanderson@verisign.com>, "irt.regdatapolicy@icann.org" <mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org> <mailto:irt.regdatapolicy@icann.org> *Subject: *Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hi,
To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made.
The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point.
Of course, if I have missed anything, would be happy to be corrected.
Thanks.
Amr
On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com <mailto:Diane.Plaut@corsearch.com>> wrote:
I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time?
Sincerely,
Diane
On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja <mailto:aelsadr@icannpolicy.ninja>> wrote:
Hi,
Makes sense to me.
Thanks.
Amr
On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org <mailto:irt.regdatapolicy@icann.org>> wrote:
Team,
I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance).
The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation.
Best,
Marc
*From:* IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org <mailto:irt.regdatapolicy-bounces@icann.org>> *On Behalf Of *Sarah Wyld *Sent:* Friday, June 21, 2019 8:26 AM *To:* irt.regdatapolicy@icann.org <mailto:irt.regdatapolicy@icann.org> *Subject:* [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
Hello Team,
I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech.
This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc.
But the Rec itself starts with "The EPDP Team recommends that *updates, if needed, are made to the contractual requirements* concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)."
Does this mean that, instead of creating a new policy section about it, we actually need to go back to other *existing *ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas.
Thanks,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 6/20/2019 3:33 AM, Dennis Chang wrote:
Dear IRT,
The recommendations 9 is open for IRT review and added to the IRT Task List as:
19
_Review Recommendation 9 Analysis: Ry&Rr to ICANN org <https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit>_
20190630
The review document with the proposed policy language has been added to the IRT Team Drive.
The task assignment is linked to it for your future reference.
https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH...
Thank you for your continuing support.
—
Kind Regards,
Dennis S. Chang
GDD Services & Engagement Program Director
Telephone: +1 213 293 7889
Skype: dennisSchang
www.icann.org <http://www.icann.org/>
_______________________________________________
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Thank you Sarah for the support on the Rec 9 approach. Scope 1.3 is the one I was thinking of. Sorry for not making this clearer. https://docs.google.com/document/d/1vERmZ21Rq3jI-taPmc2W2HVW05DIFg6WmtG_StRo... Thanks Dennis Chang From: Sarah Wyld <swyld@tucows.com> Organization: Tucows Date: Monday, July 15, 2019 at 7:42 AM To: Dennis Chang <dennis.chang@icann.org>, "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: [Ext] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Dennis, Thank you for the update. The CPH members of the IRT are satisfied with this new approach. We do have one question: could you please clarify what the Scope change was, which relates to this Rec 9 approach? I reviewed and even tried looking through the document history but I couldn't figure out what the relevant change was. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 7/5/2019 10:54 AM, Dennis Chang wrote: Hi Sarah, Yes, Rec 9 is on the agenda for the IRT meeting next week. We plan to complete Rec 5 discussion and continue down 6, 7, 8, and 9. The agenda for the IRT meetings can be found on the IRT wiki. https://community.icann.org/display/RDPIRT/2019-07-10+Registration+Data+Poli... Please feel free to propose agenda items at any time. Reminder for all IRT. Our next meeting is scheduled for 90 minutes on 10 July and you should have received the invitation from Andrea. Thanks Dennis Chang From: "IRT.RegDataPolicy" <irt.regdatapolicy-bounces@icann.org><mailto:irt.regdatapolicy-bounces@icann.org> on behalf of Sarah Wyld <swyld@tucows.com><mailto:swyld@tucows.com> Organization: Tucows Date: Friday, July 5, 2019 at 6:35 AM To: "irt.regdatapolicy@icann.org"<mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Thanks to the whole team for this useful discussion about Rec 9. Dennis/Staff - can Rec 9 be on the agenda for our upcoming meeting, please? At this time, the draft policy does not matche my understanding of the intent of this recommendation, and I think we need to to discuss as a team before we can effectively make edits in the google doc. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/24/2019 8:15 PM, Amr Elsadr wrote: Thank YOU, Diane. Amr Sent from Mobile On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: Dear Amr- Thank you for this clarification. I understand and agree. Diane Plaut General Counsel and Privacy Officer [/var/folders/lm/gc2l6l5j1hzc406w83m5v4p0fjxh_c/T/com.microsoft.Outlook/Content.MSO/C6F6FA6C.tmp] Direct +1 646-899-2806 diane.plaut@corsearch.com<mailto:diane.plaut@corsearch.com> 220 West 42nd Street, 11th Floor, New York, NY 10036, United States www.corsearch.com<http://www.corsearch.com/> Join Corsearch on Twitter<https://twitter.com/corsearch> Linkedin<https://www.linkedin.com/company/2593860/> Trademarks + Brands<http://trademarksandbrands.corsearch.com/> Customer Service/Platform Support: 1 800 SEARCH1™ (1 800 732 7241) Corsearch.USCustomerService@corsearch.com<mailto:Corsearch.USCustomerService@corsearch.com> Confidentiality Notice: This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession. From: Amr Elsadr <aelsadr@icannpolicy.ninja><mailto:aelsadr@icannpolicy.ninja> Reply-To: Amr Elsadr <aelsadr@icannpolicy.ninja><mailto:aelsadr@icannpolicy.ninja> Date: Monday, June 24, 2019 at 6:33 AM To: "Plaut, Diane" <Diane.Plaut@corsearch.com><mailto:Diane.Plaut@corsearch.com> Cc: "mcanderson@verisign.com"<mailto:mcanderson@verisign.com> <mcanderson@verisign.com><mailto:mcanderson@verisign.com>, "irt.regdatapolicy@icann.org"<mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hi, To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made. The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point. Of course, if I have missed anything, would be happy to be corrected. Thanks. Amr On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time? Sincerely, Diane On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja<mailto:aelsadr@icannpolicy.ninja>> wrote: Hi, Makes sense to me. Thanks. Amr On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Team, I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance). The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation. Best, Marc From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org<mailto:irt.regdatapolicy-bounces@icann.org>> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote: Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH... Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org/> _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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.
Dear Sarah and IRT, Thank you all for your support and productive engagement on the IRT call. Indeed, as we continue to discover the recommendations are not always easy to convert into requirements we can agree on. Such is the challenge for the implementation team. We couldn’t get to Rec 9 in our call so I’d like to see if we can make progress before the next call. Please note that I’ve added a statement on a new approach to handle Rec 9 on top of that document. I invite the IRT to consider and comment. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH... Thanks Dennis Chang From: "IRT.RegDataPolicy" <irt.regdatapolicy-bounces@icann.org> on behalf of Sarah Wyld <swyld@tucows.com> Organization: Tucows Date: Friday, July 5, 2019 at 6:35 AM To: "irt.regdatapolicy@icann.org" <irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Thanks to the whole team for this useful discussion about Rec 9. Dennis/Staff - can Rec 9 be on the agenda for our upcoming meeting, please? At this time, the draft policy does not matche my understanding of the intent of this recommendation, and I think we need to to discuss as a team before we can effectively make edits in the google doc. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/24/2019 8:15 PM, Amr Elsadr wrote: Thank YOU, Diane. Amr Sent from Mobile On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: Dear Amr- Thank you for this clarification. I understand and agree. Diane Plaut General Counsel and Privacy Officer [/var/folders/lm/gc2l6l5j1hzc406w83m5v4p0fjxh_c/T/com.microsoft.Outlook/Content.MSO/BB34789F.tmp] Direct +1 646-899-2806 diane.plaut@corsearch.com<mailto:diane.plaut@corsearch.com> 220 West 42nd Street, 11th Floor, New York, NY 10036, United States www.corsearch.com<http://www.corsearch.com/> Join Corsearch on Twitter<https://twitter.com/corsearch> Linkedin<https://www.linkedin.com/company/2593860/> Trademarks + Brands<http://trademarksandbrands.corsearch.com/> Customer Service/Platform Support: 1 800 SEARCH1™ (1 800 732 7241) Corsearch.USCustomerService@corsearch.com<mailto:Corsearch.USCustomerService@corsearch.com> Confidentiality Notice: This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession. From: Amr Elsadr <aelsadr@icannpolicy.ninja><mailto:aelsadr@icannpolicy.ninja> Reply-To: Amr Elsadr <aelsadr@icannpolicy.ninja><mailto:aelsadr@icannpolicy.ninja> Date: Monday, June 24, 2019 at 6:33 AM To: "Plaut, Diane" <Diane.Plaut@corsearch.com><mailto:Diane.Plaut@corsearch.com> Cc: "mcanderson@verisign.com"<mailto:mcanderson@verisign.com> <mcanderson@verisign.com><mailto:mcanderson@verisign.com>, "irt.regdatapolicy@icann.org"<mailto:irt.regdatapolicy@icann.org> <irt.regdatapolicy@icann.org><mailto:irt.regdatapolicy@icann.org> Subject: Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hi, To be clear, my understanding isn’t that changes to the contracts between ICANN and ROs/Registrars are unnecessary for the purpose of providing data for compliance purposes, or to satisfy the required processing activities in Purpose 5. The latter are meant to comply with relevant laws (at least the one we identified and worked on during Phase 1). What I am supporting is that there is no need to come up with Consensus Policy language for these changes to be made. The recommendation is for changes to be made to these agreements, if needed, and as Marc pointed out, recommendation 9 also points out that the scope of compliance requests is already adequately covered in the existing contracts. So changes are surely necessary, but I don’t believe the IRT can add any value at this point. Of course, if I have missed anything, would be happy to be corrected. Thanks. Amr On Jun 24, 2019, at 12:59 AM, Plaut, Diane <Diane.Plaut@corsearch.com<mailto:Diane.Plaut@corsearch.com>> wrote: I think we need to further consider this because to say it is not needed does not adequately address the changes to comply with relevant laws. The recommendation has the purpose of addressing prospective changes - can we be certain such changes will or are not needed definitely at this time? Sincerely, Diane On Jun 23, 2019, at 4:04 AM, Amr Elsadr <aelsadr@icannpolicy.ninja<mailto:aelsadr@icannpolicy.ninja>> wrote: Hi, Makes sense to me. Thanks. Amr On Jun 21, 2019, at 9:13 PM, Anderson, Marc via IRT.RegDataPolicy <irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org>> wrote: Team, I agree with Sarah on this. Recommendations #9 directs ICANN, registries and registrars to look at “the Contracts” (here referring to applicable Registry Agreements and Registrar Accreditation Agreement) making updates “if needed” to be in line with purpose 5 (contractual compliance). The recommendation notes that the contracts already provide the appropriate scope for contractual compliance requests and subsequent transfer. New consensus policy language requiring Registry operators and registrars to transfer data to ICANN is not needed, nor is that what is called for by the recommendation. Best, Marc From: IRT.RegDataPolicy <irt.regdatapolicy-bounces@icann.org<mailto:irt.regdatapolicy-bounces@icann.org>> On Behalf Of Sarah Wyld Sent: Friday, June 21, 2019 8:26 AM To: irt.regdatapolicy@icann.org<mailto:irt.regdatapolicy@icann.org> Subject: [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9 Analysis Review Hello Team, I have a question about the direction we're taking for Rec 9, and want to bring it up with the team for discussion. I am hoping we can go over it by email, as I will not be able to join you in Marrakech. This draft policy section I think tries to encompass the intent of the Recommendation, it talks about how ICANN can require Rr/Ry to provide data, and our edits yesterday focused on ensuring that applicable laws are met, only relevant data is requested, etc. But the Rec itself starts with "The EPDP Team recommends that updates, if needed, are made to the contractual requirements concerning the registration data elements for registries and registrars to transfer to ICANN Org the domain name registration data that they process when required/requested for purpose 5 (Contractual Compliance)." Does this mean that, instead of creating a new policy section about it, we actually need to go back to other existing ICANN contractual requirements and modify those to have these limitations about applicable laws, relevant data, etc.? It does not seem easily clear to me, so hopefully better minds will have some ideas. Thanks, -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392 On 6/20/2019 3:33 AM, Dennis Chang wrote: Dear IRT, The recommendations 9 is open for IRT review and added to the IRT Task List as: 19 Review Recommendation 9 Analysis: Ry&Rr to ICANN org<https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit> 20190630 The review document with the proposed policy language has been added to the IRT Team Drive. The task assignment is linked to it for your future reference. https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKH... Thank you for your continuing support. — Kind Regards, Dennis S. Chang GDD Services & Engagement Program Director Telephone: +1 213 293 7889 Skype: dennisSchang www.icann.org<http://www.icann.org/> _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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. _______________________________________________ IRT.RegDataPolicy mailing list IRT.RegDataPolicy@icann.org<mailto: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 (5)
-
Amr Elsadr -
Anderson, Marc -
Dennis Chang -
Plaut, Diane -
Sarah Wyld