[Gnso-epdp-team] Questions regarding disclosure risks
Sarah Wyld
swyld at tucows.com
Wed Sep 18 19:17:35 UTC 2019
Hello all,
During the recent EPDP face-to-face meetings in Los Angeles, several
members of the working group expressed a desire to position ICANN as the
responding party to requests for disclosure of non-public registration
data.
In order to fulfill this request, one of two things must be true. Either:
1. ICANN Org maintains a current (<24 hours) copy of the entire RDS
database; or
2. ICANN has some mechanism (contract clause) to compel the Contracted
Party to disclose the data to ICANN or the requestor
These potential scenarios raise the following questions:
1. In the first scenario, does ICANN accept the legal risks and
operational costs of maintaining its own replica of all RDS data for
gTLDs? If not, how would those risks and costs be addressed?
2. In the second scenario, will ICANN “relay” disclosed data between
the requestor and the Registry/Registrar?
3. What should be done in situations where ICANN instructs the
Registry/Registrar to disclose data (either to ICANN or the
requestor), but the contracted party has determined that the request
is not legitimate and refuses? Is this matter referred to ICANN
compliance?
Thank you,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
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