[Gnso-epdp-team] Input requested on BC input in relation to recommendation 9

Matt Serlin matt at brandsight.com
Thu Feb 7 13:41:46 UTC 2019

Struggling to keep up with and remember the context of these discussions to be honest, but I would support the text as Alan provided below. Thanks Alan for putting that forward.

As to the question of what concrete registrars can take that could be enforced upon, I’m not entirely sure what folks are looking for there but I think it’s safe to say we would be hesitant to include overly prescriptive language that could be enforced upon. Seems to me this would be more appropriate for an implementation discussion.


From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Alan Woods <alan at donuts.email>
Date: Thursday, February 7, 2019 at 6:18 AM
To: Marika Konings <marika.konings at icann.org>
Cc: "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Input requested on BC input in relation to recommendation 9

Hey all,

Sorry to be the continuous wet blanket here, but again I need to call a halt to overreach and assumptions.

The ORG process discussions regarding consent for that field, has always been about consent obtained by the registrar for the registrar's processing of the data. We have NOT discussed the transfer, or logging of this consent by the registry, or how basic matters such as change of mind / article 17 / subsequent opt-out of the registrant would be properly notified, achieved or even legally arranged by the registry.

I therefore we do NOT support the additional line from the BC as written, a as it completely circumvents the discussion necessary to achieve GDPR compliance.

The Registries therefore will only support, at this time, the recommendation as was discussed, and that is one that concerns the direct relationship and consent of a registrant with the registrar. We therefore propose the following update as clarification.

After the implementation phase-in period, the ORG FIELD will no longer be REDACTED by the registrar.

NOTE: I will defer to my Registrar colleagues as to the assumptions of the remainder of the insertion.


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On Wed, Feb 6, 2019 at 5:27 PM Marika Konings <marika.konings at icann.org<mailto:marika.konings at icann.org>> wrote:
Dear Registrar Team, all,

Per today’s action item, you are requested to provide your input on the BC suggestion that in relation to recommendation 9 – Organization field:
“Instead of a “via a process that can be determined by each registrar”   we should have concrete steps that can be enforced by ICANN.  Could the registrars identify some reasonable steps for this process?

ADD:  After the implementation phase-in period, the ORG FIELD will no longer be REDACTED by either the registry or registrar.  “

Your feedback on this input is appreciated.


Caitlin, Berry and Marika

Marika Konings
Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN)
Email: marika.konings at icann.org<mailto:marika.konings at icann.org>

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