[Gnso-epdp-team] EPDP Phase 1 Consultation from GNSO Council regarding recommendation #12

[Rafik Dammak]

Dear EPDP Team,

As the GNSO Council liaison to the EPDP Team, I wanted to provide you with
an update on the status of consultations with the ICANN Board in relation
to parts of the EPDP Phase 1 recommendations that were not adopted by the
ICANN Board (recommendation #1, purpose 2 and recommendation #12 – deletion
of org field data).

Most recently:

● The GNSO Council wrote to the ICANN Board to share its take-aways from
the engagement with the ICANN Board on this topic during ICANN65, to which
a number of

EPDP Team members contributed (see
https://gnso.icann.org/en/correspondence/gnso-council-to-icann-board-09sep19-en.pdf
).

● The ICANN Board provided a response (seehttps://
gnso.icann.org/en/correspondence/chalaby-to-drazek-14oct19-en.pdf) which
the Council discussed during its most recent meeting on Thursday 24 October
2019.

As part of its consideration of the Board’s response, focusing on
recommendation #12 –deletion of data, Council members tend to agree with
the ICANN Board that everyone has the same goal in mind here “which is
ensuring there are no inadvertent consequences of the deletion of data
while ensuring compliance with applicable laws”. The Council, based on the
input that has been provided by EPDP Team members, assumed that this notion
was already implied in recommendation #12. However, noting the Board’s
concern, the Council discussed during the 24 October meeting whether this
could be made more explicit, for example in the form of implementation
guidance, similar to how a safeguard was included in relation to the
deletion of administrative data (“prior to eliminating Administrative
Contact fields, all Registrars must ensure that each registration contains
Registered Name Holder contact information”).

Before further pursuing this approach (by way of an implementation
guidance, instead of modifying recommendation #12), the Council would like
to hear from the EPDP Team if there are any concerns about doing so or any
other input the Council should consider as it aims to conclude the
consultations with the ICANN Board.

I realize that it is short notice, but if there are any initial reactions
that I can take back to the GNSO Council before Sunday 3 November, this may
already be informative as the Council will meet with the ICANN Board during
ICANN66 and is expected to discuss this topic further during the Council
meeting which is scheduled for 6 November 2019. I will also check with
Janis to see if there are a couple of minutes we can carve out from the
Saturday session to get some initial reactions.

Looking forward to hearing from you.

Best Regards,

Rafik Dammak
GNSO Council liaison to the EPDP Team
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