[IRT.RegDataPolicy] Rec 9 Analysis Review

Sarah Wyld swyld at tucows.com
Fri Jul 5 13:36:20 UTC 2019


Thanks to the whole team for this useful discussion about Rec 9.

Dennis/Staff - can Rec 9 be on the agenda for our upcoming meeting,
please? At this time, the draft policy does not matche my understanding
of the intent of this recommendation, and I think we need to to discuss
as a team before we can effectively make edits in the google doc.

Thanks,

-- 
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392

 

On 6/24/2019 8:15 PM, Amr Elsadr wrote:
> Thank YOU, Diane. 
>
> Amr
>
> Sent from Mobile
>
>
> On Mon, Jun 24, 2019 at 10:24 PM, Plaut, Diane
> <Diane.Plaut at corsearch.com <mailto:Diane.Plaut at corsearch.com>> wrote:
>>
>> Dear Amr-
>>
>>  
>>
>> Thank you for this clarification. I understand and agree.
>>
>>  
>>
>> *Diane Plaut*
>>
>> General Counsel and Privacy Officer
>>
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>>
>> *From: *Amr Elsadr <aelsadr at icannpolicy.ninja>
>> *Reply-To: *Amr Elsadr <aelsadr at icannpolicy.ninja>
>> *Date: *Monday, June 24, 2019 at 6:33 AM
>> *To: *"Plaut, Diane" <Diane.Plaut at corsearch.com>
>> *Cc: *"mcanderson at verisign.com" <mcanderson at verisign.com>,
>> "irt.regdatapolicy at icann.org" <irt.regdatapolicy at icann.org>
>> *Subject: *Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
>>
>>  
>>
>> Hi,
>>
>>  
>>
>> To be clear, my understanding isn’t that changes to the contracts
>> between ICANN and ROs/Registrars are unnecessary for the purpose of
>> providing data for compliance purposes, or to satisfy the required
>> processing activities in Purpose 5. The latter are meant to comply
>> with relevant laws (at least the one we identified and worked on
>> during Phase 1). What I am supporting is that there is no need to
>> come up with Consensus Policy language for these changes to be made.
>>
>>  
>>
>> The recommendation is for changes to be made to these agreements, if
>> needed, and as Marc pointed out, recommendation 9 also points out
>> that the scope of compliance requests is already adequately covered
>> in the existing contracts. So changes are surely necessary, but I
>> don’t believe the IRT can add any value at this point.
>>
>>  
>>
>> Of course, if I have missed anything, would be happy to be corrected.
>>
>>  
>>
>> Thanks.
>>
>>  
>>
>> Amr
>>
>>
>>
>>     On Jun 24, 2019, at 12:59 AM, Plaut, Diane
>>     <Diane.Plaut at corsearch.com <mailto:Diane.Plaut at corsearch.com>> wrote:
>>
>>      
>>
>>     I think we need to further consider this because to say it is not
>>     needed does not adequately address the changes to comply with
>>     relevant laws. The recommendation has the purpose of addressing
>>     prospective changes - can we be certain such changes will or are
>>     not needed definitely at this time?
>>
>>      
>>
>>     Sincerely,
>>
>>      
>>
>>     Diane 
>>
>>      
>>
>>
>>     On Jun 23, 2019, at 4:04 AM, Amr Elsadr
>>     <aelsadr at icannpolicy.ninja <mailto:aelsadr at icannpolicy.ninja>> wrote:
>>
>>         Hi,
>>
>>          
>>
>>         Makes sense to me.
>>
>>          
>>
>>         Thanks.
>>
>>          
>>
>>         Amr
>>
>>
>>
>>             On Jun 21, 2019, at 9:13 PM, Anderson, Marc via
>>             IRT.RegDataPolicy <irt.regdatapolicy at icann.org
>>             <mailto:irt.regdatapolicy at icann.org>> wrote:
>>
>>              
>>
>>             Team,
>>
>>              
>>
>>             I agree with Sarah on this.  Recommendations #9 directs
>>             ICANN, registries and registrars to look at “the
>>             Contracts” (here referring to applicable Registry
>>             Agreements and Registrar Accreditation Agreement) making
>>             updates “if needed” to be in line with purpose 5
>>             (contractual compliance).
>>
>>              
>>
>>             The recommendation notes that the contracts already
>>             provide the appropriate scope for contractual compliance
>>             requests and subsequent transfer.  New consensus policy
>>             language requiring Registry operators and registrars to
>>             transfer data to ICANN is not needed, nor is that what is
>>             called for by the recommendation.
>>
>>              
>>
>>             Best,
>>
>>             Marc
>>
>>              
>>
>>              
>>
>>              
>>
>>              
>>
>>             *From:* IRT.RegDataPolicy
>>             <irt.regdatapolicy-bounces at icann.org
>>             <mailto:irt.regdatapolicy-bounces at icann.org>> *On Behalf
>>             Of *Sarah Wyld
>>             *Sent:* Friday, June 21, 2019 8:26 AM
>>             *To:* irt.regdatapolicy at icann.org
>>             <mailto:irt.regdatapolicy at icann.org>
>>             *Subject:* [EXTERNAL] Re: [IRT.RegDataPolicy] Rec 9
>>             Analysis Review
>>
>>              
>>
>>             Hello Team,
>>
>>             I have a question about the direction we're taking for
>>             Rec 9, and want to bring it up with the team for
>>             discussion. I am hoping we can go over it by email, as I
>>             will not be able to join you in Marrakech.
>>
>>             This draft policy section I think tries to encompass the
>>             intent of the Recommendation, it talks about how ICANN
>>             can require Rr/Ry to provide data, and our edits
>>             yesterday focused on ensuring that applicable laws are
>>             met, only relevant data is requested, etc. 
>>
>>             But the Rec itself starts with "The EPDP Team recommends
>>             that *updates, if needed, are made to the contractual
>>             requirements* concerning the registration data elements
>>             for registries and registrars to transfer to ICANN Org
>>             the domain name registration data that they process when
>>             required/requested for purpose 5 (Contractual Compliance)." 
>>
>>             Does this mean that, instead of creating a new policy
>>             section about it, we actually need to go back to
>>             other *existing *ICANN contractual requirements and
>>             modify those to have these limitations about applicable
>>             laws, relevant data, etc.?  It does not seem easily clear
>>             to me, so hopefully better minds will have some ideas.
>>
>>             Thanks,
>>
>>             -- 
>>
>>             Sarah Wyld
>>
>>             Domains Product Team
>>
>>             Tucows
>>
>>             +1.416 535 0123 Ext. 1392
>>
>>              
>>
>>             On 6/20/2019 3:33 AM, Dennis Chang wrote:
>>
>>                 Dear IRT,
>>
>>                  
>>
>>                 The recommendations 9 is open for IRT review and
>>                 added to the IRT Task List as:
>>
>>                 19
>>
>>                 	
>>
>>                 _Review Recommendation 9 Analysis: Ry&Rr to ICANN org
>>                 <https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit>_
>>
>>                 	
>>
>>                 20190630
>>
>>                  
>>
>>                 The review document with the proposed policy language
>>                 has been added to the IRT Team Drive.
>>
>>                 The task assignment is linked to it for your future
>>                 reference.
>>
>>                 https://docs.google.com/document/d/1tEPl9E1Geq5Z_t1dPU2DcZVdnuycx1h6pmhFweKHaaA/edit
>>
>>                  
>>
>>                 Thank you for your continuing support.
>>
>>                  
>>
>>                 — 
>>
>>                 Kind Regards,
>>
>>                 Dennis S. Chang
>>
>>                 GDD Services & Engagement Program Director
>>
>>                 Telephone: +1 213 293 7889
>>
>>                 Skype: dennisSchang
>>
>>                 www.icann.org <http://www.icann.org/>
>>
>>                  
>>
>>                  
>>
>>
>>
>>
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>>
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>>
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>>
>>                  
>>
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>>
>
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