[Gnso-epdp-team] EPDP Consensus Call #2
matt at brandsight.com
Thu Feb 7 22:49:23 UTC 2019
Hi Kurt and team,
On behalf of the RrSG ePDP reps, I’d like to submit the following feedback on the items included in Bundle 2. Overall we are in agreement with the items included with the following notes:
* References to requirements and obligations in the Temporary Specification should be rewritten since, as many have pointed out, the Temporary Specification will cease to live on past May of this year. I would defer to staff on how best to do that, but I imagine we need to include the actual language we are carrying forth from the Temporary Specification so that it can be included as part of the recommendations.
* Regarding the “Consent to publish additional information” we are supportive of this recommendation but need to clarify the Registered Name Holder is able to provide consent to publish additional contact data in the RDS for the sponsoring registrar. We would not support a framework that required the consent of the RNH to flow from the registrar to the registry, so adding that language will make it clear the consent is only related to the registrar.
Hopefully that doesn’t throw too much of a monkey wrench into our progress, but we felt important points to make.
From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Kurt Pritz <kurt at kjpritz.com>
Date: Monday, February 4, 2019 at 8:54 PM
To: EPDP <gnso-epdp-team at icann.org>
Subject: [Gnso-epdp-team] EPDP Consensus Call #2
I am trying to keep up with the comments on the list so am gaining an appreciation for the position of you members of the team. Thanks for your involvement and the tone in your emails - obviously trying to find a path to finishing each of these recommendations.
Nonetheless, I am delivering the second set of Recommendations in this consensus call process.
Please note that, given the recent discussion on the email list, I have moved three of the Recommendations out of “Bundle 2,” which includes those Recommendations where discussion is considered completed. These Recommendations are now in Bundle 3 and in blue font.
The three sections are:
The Purposes for Processing Registration Data:
Purpose 1 - Establish the rights of a Registered Name Holder
Purpose 2 - Maintaining SSR through enabling of lawful access
Purpose 3 - Enable communication with RNH
Purpose 4 - Safeguarding RNH's Registration Data
Purpose 5 - Handling Contractual Compliance
Purpose 6 - Resolution of DRPs
Purpose 7 - gTLD registration policy eligibility criteria
Recommendations considered completed in our earlier discussions:
Recommendation #2 - Commitment to consider a system for Standardized Access to non-public Registration Data
Recommendation #3 - Requirements related to accuracy
Recommendation #15 - URS / UDRP
Recommendation #16 - Instructions for RPM PDP WG
Recommendation #18 - Data processing agreements with dispute resolution providers (incl. Question #4)
Recommendation #19 - Transfer Policy
Recommendation #20 - Input to Transfer Policy review (incl. Question #5)
Recommendation #21 - Data processing agreements with non-Contracted Party entities involved in registration data processing
Recommendation #6 - Escrow Providers
New – Consent to publish additional information
Recommendations in the process of being completed or where there is disagreement:
Recommendation #9 - Organization field
Recommendation #NEW - City Field
Recommendation #10 - Email communication
Recommendation #14 - Responsible parties
Recommendation #4 - Data elements to be collected by Registrars (incl. Question #2)
Recommendation #5 - Data elements to be transferred from Registrars to Registries
Recommendation #New - Geographic Basis
Recommendation #New - Natural vs. legal
Recommendation #12 - Reasonable access
Recommendation #NEW - Implementation Transition Period
Recommendation #11 - Data retention
Recommendation #22 - Impact on other policies
Recommendation #NEW - Additional Purposes
Recommendation #8 - Redaction
Recommendation #13 - Controller Agreement
Recommendation #7 - Contractual Compliance
On this second set, please revert to me by the end of Thursday if you disagree with my assessment and if you will provide a statement for the final report. Remember that you can support a consensus position and still provide a statement. If we can in someway extend these deadlines (and we are working to do that), I will let you know.
Thank you for your attention on this and all else.
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