[council] Update re Privacy and Proxy Services Accreditation Implementation

Darcy Southwell darcy.southwell at endurance.com
Fri Nov 2 18:23:47 UTC 2018

Hi, all!


Hope everyone made it home safe and sound and has recovered from any jetlag.


Below is the latest re the Privacy and Proxy Services Accreditation
Implementation.  At a high level, I think the information highlighted in
yellow addresses Council's questions to GDD staff in Barcelona about why the
IRT has been slowed.  However, if you have further questions, please let me
know.   As liaison, I'm happy to follow up for any specific detail you may
find helpful.





From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces at icann.org> On Behalf
Of Amy Bivins
Sent: Friday, November 2, 2018 7:16 AM
To: gdd-gnso-ppsai-impl at icann.org
Subject: [Gdd-gnso-ppsai-impl] PP IRT: Next Steps


Dear Colleagues,


Following up on our discussions at ICANN63, I want to provide some
additional context around next steps for the Privacy/Proxy IRT.


As noted during several discussions in Barcelona, ICANN org believes that
there is currently a significant amount of uncertainty around interpreting
the data processing requirements of GDPR related to this type of proposed
accreditation agreement. Until we gain enough certainty to address this, we
don't believe it's prudent to move forward at our prior pace.


Areas of uncertainty include, but are not limited to:

*	The purposes of gTLD registration data, including contact data that
is protected by a privacy or proxy service;
*	The lawful bases for processing of gTLD registration data,

*	Collection;
*	Retention;
*	Transfer of data to third parties, including data escrow agents and
third-party requestors; 

*	Allocation of controller/processor obligations w/r/t gTLD
registration data; and
*	The expected solution for third-party access to non-public
registration data (and whether this might be applied to PP customer data,
which would impact implementation of the PP accreditation program). 


Many of these issues will be considered in the Expedited PDP on the
Temporary Specification for gTLD Registration Data and continued ICANN org
discussions with the European Data Protection Board. As a result, we believe
we should continue to monitor this work as we proceed to finalize other,
unrelated aspects of the proposed program requirements.


IRT Action Items

During meetings in Barcelona, many IRT members had questions about the IRT's
status. If you have additional questions or comments about next steps,
please send them to the list. In addition, if you have suggestions for items
that you believe should be discussed now, please also send those to the


I'll continue to update you via the list on work being done on this project
by ICANN org. We plan to schedule meetings periodically (every 4-6 weeks) to
ensure that you have the opportunity to raise questions or issues you would
like to discuss with the group. During these meetings, we can also discuss
progress made in other parallel efforts, and potential impacts that these
efforts may have on proposed PP accreditation requirements.






Amy E. Bivins

Registrar Services and Engagement Senior Manager

Registrar Services and Industry Relations

Internet Corporation for Assigned Names and Numbers (ICANN)

Direct: +1 (202) 249-7551

Fax:  +1 (202) 789-0104

Email: amy.bivins at icann.org <mailto:amy.bivins at icann.org> 

www.icann.org <http://www.icann.org> 


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