[Gnso-epdp-team] Question to ICANN re: Data Escrow Data Processing Agreements

Kurt Pritz kurt at kjpritz.com
Fri Dec 14 23:05:56 UTC 2018

Dear Dan and Trang:

I am writing to you in your capacity as the ICANN organisation liaisons to the EPDP Team.

As you may recall, the EPDP Team discussed Recommendation #6 from its Initial Report <https://gnso.icann.org/sites/default/files/file/field-file-attach/epdp-gtld-registration-data-specs-initial-21nov18-en.pdf> during its meeting <https://community.icann.org/display/EOTSFGRD/2018-12-04+EPDP+Team+call+%2331> on 4 December 2018.

The EPDP Team agreed to update the language of Recommendation #6 to the following: “[t]he EPDP Team recommends that ICANN Org develop legally-compliant data processing agreements with the data escrow providers.”

While you are likely aware of this recommendation, the EPDP Team thought it important to request in writing that ICANN commence development of legally-compliant data processing agreements with its approved data escrow providers. The EPDP Team discussed and documented <https://community.icann.org/display/EOTSFGRD/e.+Data+Elements+Workbooks> the associated processing activities and responsible parties for registrar data escrow and registry data escrow. Please refer to Purpose E data processing workbooks <https://community.icann.org/display/EOTSFGRD/e.+Data+Elements+Workbooks> for additional information. 

In its analysis, the EPDP Team has identified ICANN as the controller and the contracted parties and data escrow providers as processors. Accordingly, the EPDP Team encourages you to proceed with developing legally-compliant data processing agreements with those roles as described here and in the Initial Report.

If ICANN org disagrees with or wishes to discuss the EPDP Team’s request, analyis or assessment, please engage with the EPDP Team at your earliest convenience and in time to inform its deliberations as it prepares its Final Report. This, we think, will require a response prior to the end of year ICANN shutdown. 

Thanks very much for taking time to consider this. 



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