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

[Johan Helsingius]

Dear Hadia,

I suggest we don't reopen issues we have already reached agreement
on (in this case Toronto, if I am not mistaken).

	Julf

On 31-10-19 10:13, Hadia  Abdelsalam Mokhtar EL miniawi wrote:
>  
> 
> Dear Rafik,
> 
>  
> 
> Thank you for sharing with us this information and for asking for our
> input. As a matter of fact I see it necessary to modify recommendation
> number 12 and find it insufficient to merely include any changes in an
> implementation guide and let me explain why. The developed policy and
> recommendations determine the principles and rational that are to lead
> to operational outcomes. The rationale behind deleting the data of
> non-responsive registrants as opposed to redacting it, especially that
> it was originally registered by the registrant has no clear benefit. On
> the other hand losing this data could under some circumstances lead to
> an organization losing its rights to a domain name. Thus this is not an
> implementation issue this is a conceptual issue that could cause harm to
> the registrants. Even your comparison to the administration field does
> not support your logic behind moving modifications to recommendation 12
>  to the implementation guide. When the EPDP team decided that the
> administration contact information was no longer required and realizing
> that this could have a negative impact on the registrants we included
> the solution in recommendation number 29 and we did not put it as part
> of the implementation guide. Simply, because this is not an
> implementation issue that we could do in more than one way but we prefer
> one over another but because it’s a conceptual matter that has
> consequences on registrants. Modifying recommendation 12 to redact the
> data of non-responsive registrants as opposed to its deletion in my
> opinion is required.
> 
>  
> 
> Best
> 
> Hadia
> 
>  
> 
> *From:*Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] *On
> Behalf Of *Rafik Dammak
> *Sent:* Thursday, October 31, 2019 3:14 AM
> *To:* gnso-epdp-team at icann.org
> *Subject:* [Gnso-epdp-team] EPDP Phase 1 Consultation from GNSO Council
> regarding recommendation #12
> 
>  
> 
> 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
>     <http://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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