[Gnso-epdp-team] EPDP Consensus Call #2
mcanderson at verisign.com
Fri Feb 8 08:14:59 UTC 2019
Kurt and all,
On the consensus call for batch number 2, my response is largely similar to what Matt provided on behalf of registrars.
* Recommendation #2 – support as written
* Recommendation #3 – support as written
* Recommendation #15 – I cannot support as written due to the reference to maintaining the requirements of the temporary specification without clear citation as to what sections are expect to be maintained followed by text that then modifies sections of the temporary specification the recommendation just said should be maintained. If this recommendation was re-written to contain the full exact text we are recommending become policy (until superseded by recommendations from RPM or phase 2 of this ePDP), then I expect I would be able to support this.
* Recommendation #16 – support as written
* Recommendation #18 – support as written
* Recommendation #19 – I cannot support as written recommending that the language of the temporary specification be maintained. Section 7.4 of the temporary specification and the supplemental procedures referenced in Appendix G deal with the transfer policy. I expect I would be able to support this recommendation if the text was updated to incorporate that language into the final report.
* Recommendation #20 – support as written
* Recommendation #21 – support as written
* Recommendation #6 – I am fine with the language as written, however I note that this recommendation depends on the Data elements table, which is still being worked on. I don’t think it’s appropriate to have a final consensus call on this one until working group members have had a chance to review the final version of that data elements table.
* Consent to publish (new) – I agree with Matt that this language needs to be clarified that it is a consent to publish by the Registrar. My recollection of the discussion on this recommendation is that is in line with what we agreed to. We discussed that the flow of consent (and its potential withdrawal) from the registrar to the registry is problematic and unnecessary as the desired result can be accomplished by the Registrar publishing the data.
From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> On Behalf Of Kurt Pritz
Sent: Monday, February 04, 2019 10:54 PM
To: EPDP <gnso-epdp-team at icann.org>
Subject: [EXTERNAL] [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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