[Gnso-epdp-team] [Ext] Re: For your review - Proposed language for agreements reached in principle
Alan Woods
alan at donuts.email
Thu Jan 31 10:25:22 UTC 2019
Dear all,
Apologies that this is late, but alas the never-ending email inbox did it's
level best to hide this one on me!
Particularly in response to Trang's helpful reminders that the Registry
Operator's role requires some clarification in both the legal/natural and
the Recommendation 9. To that end we suggest the following edits to
Legal/natural (rather straightforward additions within the square brackets)
and an additional standalone bullet point to Recommendation 9.
*Natural vs Legal *
1. *The EPDP Team recommends that the policy recommendations in this
Final Report apply to all gTLD registrations, without requiring
Registrars [or registries] to differentiate between
registrations of legal
and natural persons, although registrars [and registries] are
permitted to
make this distinction.*
2. The EPDP Team recommends that as soon as possible ICANN Org
undertakes a study, for which the terms of reference are developed in
consultation with the community, that considers:
- The feasibility and costs *[(including both implementation costs and
potential liability costs)]* of differentiating between legal and
natural persons
- Examples of industries or other organizations that have
successfully differentiated between legal and natural persons;
- Privacy risks to registered name holders of differentiating and
not differentiating between legal and natural persons; and
- Other potential risks (if any) to registrars and registries of
not differentiating.
1. The EPDP team will discuss the Legal vs Natural issue in Phase
2. Depending on the timing of the research, its discussions may
inform the
scope of research and/or use its findings.
*NOTE 1: The original recommendation alternates between 'distinction' and
'differentiation' for no apparent reason. It should be consistent,
therefore we opted to use 'differentiate' throughout.*
*NOTE 2: The second inclusion re implementation and liability is just to
ensure there is clarity as to what 'costs' are being referred to.*
*Recommendation 9 *
We suggest the addition of the following bullet point in Recommendation 9:
- *A Registry Operator, where they believe it feasible to do so, may
publish or redact the Org Field in the RDDS output. *
Rationale: Although we defer to our registrar colleagues on this matter,
the expectation of the registry operator's as a result of this, remain
unclear. We therefore propose the bullet point to clarify our role.
This inclusion highlights the still unreviewed and hugely problematic
concept of the *transfer of consent* between Ry and Rr. The proposed
recommendation allows for the publication of the Org at the 'Opt in' option
of the registrant, and provides no further process, or clarification as to
the onward application of this consent, and indeed makes no provision for
adequate implementation of an Art 17 request to either the Ry or Rr. I have
no doubt that this process will, in future, undergo technical and legal
improvements, which may make this feasible for the registry to accept and
apply the 'Opt-In' as obtained at the registrar level, but in the interim,
our inclusion, although not purporting to affect the agreement reached for
publication of the ORG field by a registrar, now also makes way for an
optional publication by the RO (e.g. where a Registry Operator, who perhaps
based on the specific model of the Rr (e.g. brand registrars etc) and/or
based on other assurances provided to them, including the development and
availability of prerequisite technology are satisfied, that the risk of
data breach has been lowered to such an acceptable level, that the registry
operator may choose to unredact the ORG field in the Registry RDDS output.
Again apologies for delay in sending (happy to tee this up on a call), and
thank you for the consideration.
Alan
[image: Donuts Inc.] <http://donuts.domains>
Alan Woods
Senior Compliance & Policy Manager, Donuts Inc.
------------------------------
The Victorians,
15-18 Earlsfort Terrace
Dublin 2, County Dublin
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<https://www.facebook.com/donutstlds> <https://twitter.com/DonutsInc>
<https://www.linkedin.com/company/donuts-inc>
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On Mon, Jan 28, 2019 at 12:14 PM Marika Konings <marika.konings at icann.org>
wrote:
> Alan, all,
>
>
>
> In relation to recommendation #9, please find attached the new thread that
> Kurt started on this topic with propose updated. You can also find the
> latest version of the language of recommendations under review, as well as
> deadlines here: https://community.icann.org/x/VZwWBg (see status of
> review doc at the bottom of the page).
>
>
>
> Best regards,
>
>
>
> Caitlin, Berry and Marika
>
>
>
> *From: *Alan Woods <alan at donuts.email>
> *Date: *Monday, January 28, 2019 at 03:50
> *To: *"Mark Svancarek (CELA)" <marksv at microsoft.com>
> *Cc: *"James M. Bladel" <jbladel at godaddy.com>, "Mueller, Milton L" <
> milton at gatech.edu>, Alan Greenberg <alan.greenberg at mcgill.ca>, Trang
> Nguyen <trang.nguyen at icann.org>, Marika Konings <marika.konings at icann.org>,
> Sarah Wyld <swyld at tucows.com>, "gnso-epdp-team at icann.org" <
> gnso-epdp-team at icann.org>
> *Subject: *[Ext] Re: [Gnso-epdp-team] For your review - Proposed language
> for agreements reached in principle
>
>
>
> Hey all,
>
>
>
> Perhaps its the mountain of emails on umpteen topics, but I'm now lost on
> this recommendation. Perhaps someone refresh the thread with where the text
> of recommendation 9 now stands after all the back and forth?
>
>
>
> Thank you!
>
>
>
> Alan
>
>
>
>
>
> [image: Image removed by sender. Donuts Inc.][donuts.domains]
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__donuts.domains&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=7fwdUqyPKtxhvDjFIxkgJQv96VqXEYLcH5ES2sEfFGU&s=9XT77yzqavOgen8XEbBf4aQf3siFtt6Z8T2LgyCp-kk&e=>
>
> *Alan Woods*
>
> Senior Compliance & Policy Manager, Donuts Inc.
> ------------------------------
>
> The Victorians,
>
> 15-18 Earlsfort Terrace
> Dublin 2, County Dublin
> Ireland
>
> [image: Image removed by sender.][facebook.com]
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> [image: Image removed by sender.] [twitter.com]
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>
>
>
> Please NOTE: This electronic message, including any attachments, may
> include privileged, confidential and/or inside information owned by Donuts
> Inc. . Any distribution or use of this communication by anyone other than
> the intended recipient(s) is strictly prohibited and may be unlawful. If
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> this message and then delete it from your system. Thank you.
>
>
>
>
>
> On Thu, Jan 24, 2019 at 8:39 PM Mark Svancarek (CELA) via Gnso-epdp-team <
> gnso-epdp-team at icann.org> wrote:
>
> That works for me.
>
>
>
> *From:* James M. Bladel <jbladel at godaddy.com>
> *Sent:* Thursday, January 24, 2019 09:42
> *To:* Mueller, Milton L <milton at gatech.edu>; Alan Greenberg <
> alan.greenberg at mcgill.ca>; Mark Svancarek (CELA) <marksv at microsoft.com>;
> Trang Nguyen <trang.nguyen at icann.org>; Marika Konings <
> marika.konings at icann.org>; Sarah Wyld <swyld at tucows.com>;
> gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
>
>
> Taking all of these comments on board, as well as consulting other
> registrars, I think step 3.3 should provide Registrars the option to
> “delete” OR “redact” upon no response from the Registrant.
>
>
>
> Thanks—
>
>
> J.
>
>
>
>
>
> *From: *"Mueller, Milton L" <milton at gatech.edu>
> *Date: *Thursday, January 24, 2019 at 6:09 AM
> *To: *Alan Greenberg <alan.greenberg at mcgill.ca>, "Mark Svancarek (CELA)" <
> marksv at microsoft.com>, Trang Nguyen <trang.nguyen at icann.org>, "James M.
> Bladel" <jbladel at godaddy.com>, Marika Konings <marika.konings at icann.org>,
> Sarah Wyld <swyld at tucows.com>, "gnso-epdp-team at icann.org" <
> gnso-epdp-team at icann.org>
> *Subject: *RE: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
>
>
> We (NCSG) prefer deletion. If the registrant has been notified about the
> change and they choose not to respond, then they have chosen not to opt in.
> Under the principle of both data minimization and opt-in, the only legal
> path is to delete the information.
>
>
>
> --MM
>
>
>
> *From:* Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org
> <gnso-epdp-team-bounces at icann.org>] *On Behalf Of *Alan Greenberg
> *Sent:* Wednesday, January 23, 2019 1:57 PM
> *To:* Mark Svancarek (CELA) <marksv at microsoft.com>; Trang Nguyen <
> trang.nguyen at icann.org>; James M. Bladel <jbladel at godaddy.com>; Marika
> Konings <marika.konings at icann.org>; Sarah Wyld <swyld at tucows.com>;
> gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
>
>
> I prefer redaction as well. It means there needs to be a flag to indicate
> it can be publicly displayed, but I agree with the ICANN Org concern about
> losing potentially important imformation.
>
> Alan
>
> At 22/01/2019 06:25 PM, Mark Svancarek \(CELA\) via Gnso-epdp-team wrote:
>
> Regarding redaction/deletion, I think I prefer redaction. I defer to
> James whether redaction is technically more annoying than deletion.
>
>
>
> *From:* Trang Nguyen <trang.nguyen at icann.org>
> *Sent:* Tuesday, January 22, 2019 3:14 PM
> *To:* Mark Svancarek (CELA) <marksv at microsoft.com>; James M. Bladel <
> jbladel at godaddy.com>; Marika Konings <marika.konings at icann.org>; Sarah
> Wyld <swyld at tucows.com>; gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
> Dear All,
>
> Regarding the organization field, ICANN org flagged the following in the
> AC chat during the Toronto face-to-face meeting last week. We wanted to
> flag this again for your consideration/discussion as you work to finalize
> the recommendation: Some registrants use the organization field to identify
> themselves, an example of this is ICANN where the registrant name is
> “Domain Administrator†and organization is “ICANN†(
> https://www.godaddy.com/whois/results.aspx?domain=icann.org"
> [nam06.safelinks.protection.outlook.com]
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__nam06.safelinks.protection.outlook.com_-3Furl-3Dhttps-253A-252F-252Fwww.godaddy.com-252Fwhois-252Fresults.aspx-253Fdomain-253Dicann.org-2526quot-26data-3D02-257C01-257Cmarksv-2540microsoft.com-257Cd697d549db534540376208d682233f99-257C72f988bf86f141af91ab2d7cd011db47-257C1-257C0-257C636839485260002826-26sdata-3DVMHs470pGkcMYvXQwoh4oQ-252BecZWfSuk-252FHljPwRJ4-252Fsg-253D-26reserved-3D0&d=DwMFaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=7_PQAir-9nJQ2uB2cWiTDDDo5Hfy5HL9rSTe65iXLVM&m=7fwdUqyPKtxhvDjFIxkgJQv96VqXEYLcH5ES2sEfFGU&s=WbpSXgoww9Q7dCzBkDjbwp-TEgFv9TteSh3v8I4bf0Y&e=>
> ;). Under 3(c) in James’s email below, if registrants do not respond the
> organization field would be deleted. This could result in a number of
> registrations where identifying information for registrants would no longer
> be available. It’s unclear if deletion is needed or whether redaction of
> the information would achieve the intent of the recommendation?
>
> Regarding the Natural vs. Legal recommendation, the proposed text of the
> recommendation says: “…without requiring Registrars to differentiate
> between registrations of legal and natural persons, although registrars are
> permitted to make this distinction.†Is the intent of the recommendation
> to limit the requirement to registrars only, or should the text include
> registries as well?
>
> Best,
>
> Dan and Trang
> ICANN Org Liaisons
>
>
> *From: *Gnso-epdp-team < gnso-epdp-team-bounces at icann.org> on behalf of
> "Mark Svancarek (CELA) via Gnso-epdp-team" <gnso-epdp-team at icann.org >
> *Reply-To: *"Mark Svancarek (CELA)" <marksv at microsoft.com>
> *Date: *Tuesday, January 22, 2019 at 8:32 AM
> *To: *"James M. Bladel" <jbladel at godaddy.com>, Marika Konings <
> marika.konings at icann.org >, Sarah Wyld <swyld at tucows.com>, "
> gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org >
> *Subject: *Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
> Makes sense, thanks for clarifying.
>
> *From:* James M. Bladel <jbladel at godaddy.com>
> *Sent:* Tuesday, January 22, 2019 8:08 AM
> *To:* Mark Svancarek (CELA) <marksv at microsoft.com>; Marika Konings <
> marika.konings at icann.org >; Sarah Wyld <swyld at tucows.com>;
> gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
> I think we need to standardize on what the “Registrant Org†field is
> telling us. Some registrars use this field to indicate that the
> Organization is the registrant, so if the end user deletes this
> information, it has the effect of re-assigning the name to natural person
> listed as the Registrant.
>
> J.
>
>
> *From: *"Mark Svancarek (CELA)" <marksv at microsoft.com>
> *Date: *Tuesday, January 22, 2019 at 8:05 AM
> *To: *"James M. Bladel" <jbladel at godaddy.com>, Marika Konings <
> marika.konings at icann.org >, Sarah Wyld <swyld at tucows.com>, "
> gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org >
> *Subject: *RE: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
> I think I agree: can you clarify what this means?
>
> - *Registration is re-assigned to Registrant (natural person)*
>
>
>
>
> *From:* Gnso-epdp-team < gnso-epdp-team-bounces at icann.org> *On Behalf Of *James
> M. Bladel
> *Sent:* Tuesday, January 22, 2019 6:30 AM
> *To:* Marika Konings <marika.konings at icann.org >; Sarah Wyld <
> swyld at tucows.com>; gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
> Hi Folks –<
>
> Let’s try to untangle this with the aim on simplicity & minimizing
> confusion (epdp and registrants). Here are my recollections from Toronto:
>
> Between the adoption of ePDP and some future date (Jan 1 2020?)
>
> 1. Redact Registrant ORG field.
> 2. Registrars contact Registrants who have data in this field, and ask
> them to confirm the data is correct & accurate.
> 3. Based upon Registrant Action –
>
>
> 1. Registrant Confirms or Corrects – Data remains n Org field.
> 2. Registrant Declines – Data in Org field is DELETED, Registration
> is re-assiigned to Registrant (natural person)
> 3. Registrant No Response – Data in Org field is DELETED,
> Registration is re-assigned to Registrant (natural person)
>
> After future date –
> New registrations would present some disclosure/disclaimer when data is
> entered in the ORG field
>
> 1. Registrars are free to innovate on the exact process, either an
> opt-in, or pop-up or locked/grayed out field, etc.
>
> ORG will be treated as the legal-person registrant of the domain name,
> with the Natural Person listed as a point of contact. ORG field will be
> published, if it contains data.
>
> *From: *Gnso-epdp-team < gnso-epdp-team-bounces at icann.org> on behalf of
> Marika Konings <marika.konings at icann.org >
> *Date: *Tuesday, January 22, 2019 at 6:02 AM
> *To: *Sarah Wyld <swyld at tucows.com>, " gnso-epdp-team at icann.org" <
> gnso-epdp-team at icann.org >
> *Subject: *Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
> Thanks, Sarah, for flagging this. We actually went back and forth on this
> looking at the transcript and our understanding was that opt-in was for
> existing registrations, while opt-out would apply to any new registrations
> (with the appropriate information being provided to the registrant that the
> information for the Organization field would be published, unless indicated
> differently). However, as this was James’s proposal, we would like to ask
> him to confirm what the original proposal was so that the recommendation
> can be adjusted, as needed.
>
> James, over to you.
>
> Best regards,
>
> Caitlin, Berry and Marika
>
> *From: *Gnso-epdp-team < gnso-epdp-team-bounces at icann.org> on behalf of
> Sarah Wyld <swyld at tucows.com>
> *Organization: *Tucows
> *Date: *Tuesday, January 22, 2019 at 05:36
> *To: *" gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org >
> *Subject: *Re: [Gnso-epdp-team] For your review - Proposed language for
> agreements reached in principle
>
>
> Good morning,
>
> I notice a significant difference between the Toronto Day 3 notes and the
> draft below, regarding the Organization field.
>
>
>
> Day 3 notes - "Principles for Redaction of Registrant Organization Field"
> #4:
>
> 4. Upon (1) the registration of a Registered Name sponsored by Registrar
> or (2) the transfer of the sponsorship of a Registered Name to Registrar,
> the Registrar MUST inform all Registered Name Holders that the Registrant
> Org field will be redacted unless the Registered Name Holder affirmatively
> opts in to the publication of the Registrant Org field.
>
>
>
> Updated Recommendation #9 below:
>
> 4. Upon (1) the registration of a Registered Name sponsored by Registrar
> or (2) the transfer of the sponsorship of a Registered Name to Registrar,
> the Registrar MUST inform the Registered Name Holder that the Registrant
> Org field will be published unless the Registered Name Holder affirmatively
> opts in to redaction of the Registrant Org field.
>
>
>
> The Org field should be redacted by default, and the Registered Name
> Holder should be able to opt-in to publication. This aligns with the
> principle of Privacy by Default and is what we agreed on during the Day 3
> meeting.
>
> Thanks,
>
> --
>
>
>
> Sarah Wyld
>
>
>
> Tucows
>
>
>
> +1.416 535 0123 Ext. 1392
>
>
>
>
>
>
>
>
>
>
> On 1/22/2019 12:33 AM, Marika Konings wrote:
> Dear EPDP Team,
>
> In Toronto, we reached agreement in principle on several issues but did
> not have time to develop language to which the team agreed. To move that
> discussion forward, the support team has developed the proposed language
> below for discussion and inclusion in the Final Report. Please review this
> language with your group to ensure it aligns with the agreement that was
> reached. If you are of the view that it does not conform to the agreement,
> please:
>
>
> Respond to this message and change the subject line to the topic of the
> recommendation about which you have concerns; Outline your concerns,
> focusing on how the proposed language does not reflect the principle
> agreement reached, and; Propose edits that would address your concerns that
> are in line with the agreement reached.
>
> The deadline for doing so is Thursday 25 January so that there is
> sufficient time to review and discuss any concerns. If no concerns are
> raised, this language will be incorporated into the draft Final Report for
> your review. Best regards, Caitlin, Berry and Marika ========= Based on the
> discussions during the F2F meeting in Toronto, the following updated
> language is provided for EPDP Team review on the following topics /
> recommendations:
>
> Natural vs. legal
>
> Draft recommendation1) The EPDP Team recommends that the policy
> recommendations in this Final Report apply to all gTLD registrations,
> without requiring Registrars to differentiate between registrations of
> legal and natural persons, although registrars are permitted to make this
> distinction.2) The EPDP Team recommends that as soon as possible ICANN
> Org undertakes a study, for which the terms of reference are developed in
> consultation with the community, that considers:
>
> - The feasibility and costs of distinguishing between legal and
> natural persons;
> - Taking into account examples of industries or other organizations
> where this has been successfully done;
> - Consider privacy risks to registrants, and;
> - Consider the risks of not differentiating.
>
>
> 3) Depending on the timing of the research, whether to inform the
> scope or make use of its findings, the EPDP team will discuss the Legal vs
> Natural issue in Phase 2.
>
> Consent to publish additional contact information
>
> Agreement in principle: In its discussion on consent, the Temporary
> Specification omitted RNH email as a piece of information to which the
> registrant could consent to publication. This draft recommendation corrects
> that omission. Draft recommendationThe EPDP Team recommends that, as soon
> as commercially reasonable, Registrar must provide the opportunity for the
> Registered Name Holder to provide its Consent to publish additional contact
> information.
>
> Organization Field
>
> Agreement in principle: Rather than requiring the publication or
> redaction of the Organization Field, a phased approach was suggested by
> Team Members that gained general agreement. Updated Recommendation #9
> 1. The EPDP Team recommends that Registrars MAY begin
> redacting the Registrant Org field immediately.2. For
> existing registrants: the EPDP Team recommends that Registrars MUST notify
> all existing Registered Name Holders that the Registrant Org field will be
> treated as non-personal data for new registrants beginning on [x date - to
> be agreed upon during the implementation of this Policy], and accordingly,
> the field will be published for new registrants in the freely-accessible
> directory beginning on [x date]. However, if existing Registered Name
> Holders wish to have its Organization field published within the
> freely-accessible database, it must affirmatively consent to the
> publication by opting in. If the Registered Name Holder affirmatively opts
> in to the publication of its existing (or modified) Registrant
> Organization, the Registrar may publish the Registrant Organization Field
> immediately and/or on the agreed-upon [x] date.3. The EPDP
> Team recommends if the existing Registered Name Holder does not
> affirmatively opt in to the publication of its Registrant Organization
> field, the Registrar will show the existing Registrant Organization Field
> but the field MAY be left blank.4. Upon (1) the registration
> of a Registered Name sponsored by Registrar or (2) the transfer of the
> sponsorship of a Registered Name to Registrar, the Registrar MUST inform
> the Registered Name Holder that the Registrant Org field will be published
> unless the Registered Name Holder affirmatively opts in to redaction of the
> Registrant Org field.
>
> Deferring consideration of new proposed purposes to phase 2
>
> Agreement in principle: With regards to proposed Purpose O, the Purpose
> supporting ARS, and the additional purposes received through public
> comment, the EPDP Team understands some legal clarification is required as
> to whether those purposes can fall under existing Purposes. Additional
> complexities were introduced. Therefore, the Team decided to put off this
> discussion for Phase 2 where the EPDP Charter makes it clear that
> additional Purposes are, in fact, anticipated. Draft recommendationThe EPDP
> Team commits to considering in Phase 2 of its work whether additional
> purposes should be considered to facilitate research carried out by
> ICANN’s Office of the Chief Technology Officer (OCTO) as well as the
> continuation of the WHOIS Accuracy Reporting System (ARS). This
> consideration should be informed by legal guidance on if/how provisions in
> the GDPR concerning research apply to ICANN Org. Marika KoningsVice
> President, Policy Development Support – GNSO, Internet Corporatioon for
> Assigned Names and Numbers (ICANN) Email: marika.konings at icann.org
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> ---------- Forwarded message ----------
> From: Kurt Pritz <kurt at kjpritz.com>
> To: EPDP <gnso-epdp-team at icann.org>
> Cc:
> Bcc:
> Date: Fri, 25 Jan 2019 11:13:26 -0800
> Subject: [Gnso-epdp-team] Organization Field - Updated - Recommendation #9
>
> Hi Everyone:
> In the ongoing and seemingly never-ending attempt to close discussion on
> Recommendations for the Final Report via email discussion, below please
> find amended wording for Recommendation 9, having to do with the
> publication / redaction of the Organization field.
>
> After posting of the initial version, I read the email list comment and
> was drawn to James’ rather clean outline, as opposed to my less clear
> earlier proposal. Therefore, I took the liberty of reorganizing the
> proposed Recommendation somewhat, taking into account not only James
> structure but also the email comments before and after that (as well as the
> meeting notes). The result is below. I also placed the procedure itself as
> part of our “implementation advice” as there will be operational details to
> figure out. The implementation effort can ensure that those “details” are
> consonant with the policy goals.
>
>
> *Proposed Recommendation #9*
>
> The EPDP Team recommends that:
>
> - The Organization field will be published if that publication is
> acknowledged or confirmed by the registrant via a process that can be
> determined by each registrar. If the registered name holder does not
> confirm the publication, the Organization field can be redacted or the
> field contents deleted at the option of the registrar.
>
> - The implementation will have a phase-in period to allow registrars
> the time to deal with existing registrations and develop procedures.
>
> - In the meantime, registrars will be permitted to redact the
> Organization Field.
>
>
> *Implementation advice:* the implementation review team should consider
> the following implementation model discussed by the EPDP Team:
>
> For existing registrations, the first step will be to confirm the
> correctness / accuracy of the existing Organization field data.
>
> For the period between the adoption of EPDP policy recommendations and
> some future “date certain” to be determined by the implementation review:
>
> 1) Registrars will redact the Organization field
>
> 2) Registrars will contact the registered name holders that have
> entered data in the Organization field and request review and confirmation
> that the data is correct.
>
> a. If the registered name holder confirms or corrects the data the
> data will remain in the Organization field.
>
> b. If the registrant declines, or does not respond to the query, the
> Registrar may redact the Organization field, or delete the field contents.
> If necessary, the registration will be re-assigned to the Registered Name
> Holder.
>
> 3) If Registrar chooses to publish the Registrant Organization field,
> it will notify these registered name holders that of the “date certain,”
> the Organization field will be treated as non-personal data and be
> published, for those Registered Names Holders who have confirmed the data
> and agreed to publication.
>
> For new registrations, beginning with the “date certain”:
>
> 1) New registrations will present some disclosure, disclaimer or
> confirmation when data is entered in the Organization field. Registrars are
> free to develop their own process (e.g., opt-in, pop-up advisory or
> question, locked/grayed out field).
>
> 2) If the registered name holder confirms the data and agrees to
> publication:
>
> a. the data in the Organization field will be published,
>
> b. The Organization will be listed as the Registered Name Holder.
>
> c. The name of the registered name holder (a natural person) will be
> listed as the point of contact at the Registrant Organization.
>
>
> *Actions:* Please indicate on the mailing list whether you have any
> concerns about these modifications and/or what other aspects of this
> recommendation should be discussed.
>
> Deadline for comment: Tuesday 29 Jan.
>
> Thank you and best regards,
>
> Kurt
>
>
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