[IRT.RegDataPolicy] Rec 9 Analysis Review
Sarah Wyld
swyld at tucows.com
Mon Jul 15 14:42:58 UTC 2019
Hello Dennis,
Thank you for the update.
The CPH members of the IRT are satisfied with this new approach.
We do have one question: could you please clarify what the Scope change
was, which relates to this Rec 9 approach? I reviewed and even tried
looking through the document history but I couldn't figure out what the
relevant change was.
Thanks,
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 7/5/2019 10:54 AM, Dennis Chang wrote:
>
> Hi Sarah,
>
>
>
> Yes, Rec 9 is on the agenda for the IRT meeting next week.
>
> We plan to complete Rec 5 discussion and continue down 6, 7, 8, and 9.
>
> The agenda for the IRT meetings can be found on the IRT wiki.
>
> https://community.icann.org/display/RDPIRT/2019-07-10+Registration+Data+Policy+Implementation+IRT+Meeting
>
> Please feel free to propose agenda items at any time.
>
>
>
> Reminder for all IRT.
>
> Our next meeting is scheduled for 90 minutes on 10 July and you should
> have received the invitation from Andrea.
>
>
>
> Thanks
>
> Dennis Chang
>
>
>
> *From: *"IRT.RegDataPolicy" <irt.regdatapolicy-bounces at icann.org> on
> behalf of Sarah Wyld <swyld at tucows.com>
> *Organization: *Tucows
> *Date: *Friday, July 5, 2019 at 6:35 AM
> *To: *"irt.regdatapolicy at icann.org" <irt.regdatapolicy at icann.org>
> *Subject: *Re: [IRT.RegDataPolicy] Rec 9 Analysis Review
>
>
>
> 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
>
> /var/folders/lm/gc2l6l5j1hzc406w83m5v4p0fjxh_c/T/com.microsoft.Outlook/Content.MSO/C6F6FA6C.tmp
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> Direct +1 646-899-2806
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> *From: *Amr Elsadr <aelsadr at icannpolicy.ninja>
> <mailto:aelsadr at icannpolicy.ninja>
> *Reply-To: *Amr Elsadr <aelsadr at icannpolicy.ninja>
> <mailto:aelsadr at icannpolicy.ninja>
> *Date: *Monday, June 24, 2019 at 6:33 AM
> *To: *"Plaut, Diane" <Diane.Plaut at corsearch.com>
> <mailto:Diane.Plaut at corsearch.com>
> *Cc: *"mcanderson at verisign.com"
> <mailto:mcanderson at verisign.com> <mcanderson at verisign.com>
> <mailto:mcanderson at verisign.com>,
> "irt.regdatapolicy at icann.org"
> <mailto:irt.regdatapolicy at icann.org>
> <irt.regdatapolicy at icann.org> <mailto: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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