Country should not be listed in 1.1.4.4. Unless the goal of ICANN org is to release a confusing, vague, inconsistent and thus ultimately unenforceable policy. Alex ___________ *Alex Deacon* Cole Valley Consulting alex@colevalleyconsulting.com +1.415.488.6009 On Thu, Jan 13, 2022 at 9:16 AM Sarah Wyld via IRT.RegDataPolicy < irt.regdatapolicy@icann.org> wrote:

Hello Team,

Forwarding this google docs comment thread (below) for discussion.

Re the Registrant Country, listed as 1.1.4.4 in the new Section 10. This data element is not subject to redaction (as Dennis pointed out, section 1.2.1 does not include it).

I don’t understand why this element is found in 1.1.4 (“In responses to RDDS queries and subject to the redaction requirements outlined in the subsequent sections, (1) Registrar MUST Publish the following data elements and (2) Registry MUST Publish the following data elements if transferred from the Registrar:”).

It seems to me that it belongs in 1.1.2 (“In responses to RDDS queries, Registrar and Registry Operator MUST Publish the following data elements if collected or generated:”) because the Registrar will always collect this field but the Registry may not, and this field is not subject to redaction requirements.

I know this was on our agenda for Dec 15 but my notes about our homework were that following that meeting we were supposed to review the section in detail and come back with any concerns before January 7, which I did. I’m not sure why the comment thread has been resolved in the OneDoc since clearly two members of this IRT do have questions about it which have not been resolved.

I would like to understand the reasoning for putting this data element in the ‘might be redacted’ section, when it is not permissible to redact this data element.

Thank you,

--

*Sarah Wyld*, CIPP/E

Policy & Privacy Manager

Pronouns: she/they

swyld@tucows.com

+1.416 535 0123 Ext. 1392

*From: *Dennis Chang (Google Docs) <comments-noreply@docs.google.com> *Sent: *January 12, 2022 1:40 PM *To: *swyld@tucowsinc.com *Subject: *IRT.OneDoc RegDat... - This field is not subject to redactio...

Dennis Chang replied to a comment in the following document

IRT.OneDoc RegDataPolicy20201005 <https://docs.google.com/document/d/1SVFkoI6RmrVVz--RrVLSOj1bmz1qLb7_JTuvt7At4Uo/edit?disco=AAAAShi7Tb8&usp=comment_email_document&ts=61df2085&usp_dm=false>

Registrant Country

Sarah Wyld

This field is not subject to redaction, does it belong in 1.1.2 instead?

Alex Deacon

agree country should be in 1.1.2

Dennis ChangNew

the section 10 needs to be read together. the registrant country is not included in 1.2.1 as you'll note. therefore this data element needs to be here. this was discussed at the IRT meeting 20211215.

Open <https://docs.google.com/document/d/1SVFkoI6RmrVVz--RrVLSOj1bmz1qLb7_JTuvt7At4Uo/edit?disco=AAAAShi7Tb8&usp=comment_email_discussion&ts=61df2084&usp_dm=false>

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