[IRT.RegDataPolicy] IRT Liaison report on Rec7 during the 20Aug2020 GNSO Council Meeting
Sarah Wyld
swyld at tucows.com
Wed Sep 9 18:10:19 UTC 2020
Hello team,
I'd like us to return to Roger's initial email, which I think had some
very valuable points in it that have been a bit passed over. I've
attached it here for reference (hope it comes through).
Recommendation #7 says the data "must be transferred from registrar to
registry provided an appropriate legal basis exists and data processing
agreement is in place."
Whether the Thick Whois Transition Policy is itself the grounds for a
legitimate interest in the data or not is beside the point; our duty in
this IRT is to implement the recommendations, and omitting that language
from the final Policy would mean we lose requirements which the Phase 1
EPDP team found important enough to specifically include in the
recommendation.
If a Registry's implementation of the Thick Whois Transition Policy is
such that all the data elements listed in Rec 7 are required, then
that's fine as long as the registry provides an appropriate data
processing agreement to the registrar. But it's not appropriate for us
as the IRT to modify the Policy by removing this requirement.
Thank you,
Sarah
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
On 9/9/2020 12:21 PM, King, Brian via IRT.RegDataPolicy wrote:
>
> Thanks, Stephanie.
>
>
>
> Yes, whether a registry is in the US or on the moon, SCCs are a lawful
> way to transfer data out of Europe. Ironically the “problem” as you
> say is actually part of the solution to reconciling Thick WHOIS with
> the Phase 1 policy since they address concerns raised about
> cross-border data transfer.
>
>
>
> To your final point below, the Bird & Bird legal advice was obtained
> post-GDPR, so we don’t need to rely on legal advice received during
> the Thick WHOIS PDP.
>
>
>
> Since we have legal advice confirming that a legal basis exists, and
> we have identified a lawful way of transferring Thick WHOIS data
> across borders, it seems there are no further reasonable concerns
> requiring the conditional language in Rec 7, and we can proceed with
> the language suggested by Staff.
>
>
>
> *Brian J. King*
> Director of Internet Policy and Industry Affairs, IP Group
>
>
> T +1 443 761 3726
>
> _clarivate.com_
>
>
> *From:* Stephanie E Perrin <stephanie at digitaldiscretion.ca>
> *Sent:* Wednesday, September 9, 2020 10:59 AM
> *To:* King, Brian <Brian.King at markmonitor.com>;
> irt.regdatapolicy at icann.org
> *Subject:* Re: [IRT.RegDataPolicy] IRT Liaison report on Rec7 during
> the 20Aug2020 GNSO Council Meeting
>
>
>
> I am aware. However, lets be clear. Verisign is the gorilla in this
> room. Are they not in the US? I will not belabor the competition
> issues that underlined the whole thick thin decision so many years ago
> (which still in my view persist and justify keeping Verisgn thin) but
> we are talking here about a US transfer, in the main.
>
> SCCs are another matter, as Schrems himself says. Another problem for
> another day.
>
> Finally, the legal advice that the Thick PDP received in my view was
> woefully off base. We should not, in all conscience, point to that
> decision, based on that advice.
>
> Cheers
>
> SP
>
> On 2020-09-09 9:59 a.m., King, Brian wrote:
>
> Hi Stephanie and team,
>
>
>
> In their memo, Bird & Bird cites to at least the Thick WHOIS Final
> Report and the ICANN Board Resolution adopting it, both of which
> contain the rationale for implementing Thick WHOIS.
>
>
>
> To be clear, Schrems II is a red herring. EU/US Privacy Shield
> never covered data transfer from EU-based registrars to registries
> in any non-US jurisdiction, and was never going to be the solution
> for Thick WHOIS data transfer. A different lawful transfer
> mechanism has always been required, using standard contractual
> clauses (SCCs) for example
> (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__ec.europa.eu_info_law_law-2Dtopic_data-2Dprotection_international-2Ddimension-2Ddata-2Dprotection_standard-2Dcontractual-2Dclauses-2Dscc-5Fen&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=B26njLf88JPq19QisV3W53Gh6cbitmWV2kzdPgYBJHk&s=iVYMueKcIMHA9fqRenrlrbjwG-g8OaYfkr5kbUOZ5FU&e=>).
>
>
>
>
> Without giving legal advice, this is a big part of why ICANN
> facilitated a standardized RRA Amendment to cover data processing
> between registries and registrars:
> https://www.icann.org/resources/pages/rra-amendment-procedure-gtld-registration-data-specs-2018-07-02-en
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_resources_pages_rra-2Damendment-2Dprocedure-2Dgtld-2Dregistration-2Ddata-2Dspecs-2D2018-2D07-2D02-2Den&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=B26njLf88JPq19QisV3W53Gh6cbitmWV2kzdPgYBJHk&s=ioTrFnFrIDEn79jdeB5UNI9A4XFo5t65Ml60irHgt3Y&e=>.
> Those familiar with SCCs will find the language in the RRA
> Amendment template very familiar.
>
>
>
> *Brian J. King*
> Director of Internet Policy and Industry Affairs, IP Group
>
>
> T +1 443 761 3726
>
> _clarivate.com_
>
>
>
>
> *From:* IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org>
> <mailto:irt.regdatapolicy-bounces at icann.org> *On Behalf Of
> *Stephanie E Perrin
> *Sent:* Tuesday, September 8, 2020 6:26 PM
> *To:* irt.regdatapolicy at icann.org <mailto:irt.regdatapolicy at icann.org>
> *Subject:* Re: [IRT.RegDataPolicy] IRT Liaison report on Rec7
> during the 20Aug2020 GNSO Council Meeting
>
>
>
> The Bird and Bird opinion as to the legal basis of the transfer of
> the data to the registry under the thick policy is very curious.
> I wonder if someone can point me to the briefing material that
> they received on the rational for the Thick WHois policy, and the
> previous "thin Policy".
>
> I completely agree with Theo that post Schrems II, the transfer of
> personal data to the registry without a technical reason to do so
> is difficult to justify.
>
> Stephanie Perrin
>
>
>
> On 2020-09-08 3:35 p.m., Theo Geurts wrote:
>
> As long the IWGDPT does not change their opinion of the below.
>
> And taking in account the Schrems II decision ie no more
> privacy shield (which was not taken into account by B&B) and
> NOW should be taken into account, a legal basis is required
> and by the logic of Brian we can simply agree that we leave
> the recommendation approved by the board as is and include a
> legal basis. If this things ends at the DPA's I rather side
> with the opinion of the IWGDPT (the DPA's of this world) than
> rely my legal basis of B&B where I could not consult on.
>
> Oh two pointers , adequacy standard, well as it is now, the
> USA will not reach that standard unless things will change a
> lot in favor of data protection. And the technology to permit
> the data to remain in the jurisdiction of the registrar, well
> we have that for decades now and RDAP even makes things easier..
>
>
>
> *ICANN should explicitly address the issue of transborder
> dataflow in its policies, and ensure that data transfers
> ensure adequate data protection is maintained. 19 2013
> Registrar Accreditation Agreement,
> https://www.icann.org/resources/pages/approved-withspecs-2013-09-17-en
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_resources_pages_approved-2Dwithspecs-2D2013-2D09-2D17-2Den&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ksGqw06mx_8tgEzKe_n3S7oqAZSXndVQSnz8Y-V60vs&s=QyAr_YqzyezwNSZCrb5yOmtXQ7c1xAMot81z4Lf40GA&e=>
> - 9 - The issue of where the data is held has not been a
> subject of previous commentary from the IWGDPT. It is the
> understanding of the IWGDPT that under the recently completed
> new policy known as “Thick WHOIS”, registrars who formerly
> maintained the data of gTLD registrants themselves and
> provided WHOIS access through port 43, are now transferring
> the data to the registries, including the big registries such
> as .com, .net, and others. This represents 75% of the gTLD
> registrations, which means there will be significant transfers
> of personal data to the United States, where, for instance,
> the largest registry operator Verisign holds its data. It is
> important that data be protected in a manner that ensures
> continuous protection to the “adequacy” standard, and that
> registrants are aware of this transfer. If technology permits
> the data to remain in the jurisdiction of the registrant or
> registrar, we would recommend limiting dataflows to only those
> which are absolutely necessary. *
>
> Thanks,
>
> Theo
>
> Op 8-9-2020 om 19:18 schreef King, Brian via IRT.RegDataPolicy:
>
> Hi all,
>
>
>
> If it helps to break the tie here, Bird & Bird confirmed
> that a legal basis exists.
> https://community.icann.org/download/attachments/102138857/ICANN%20-%20Memo%20on%20thick%20Whois%5B1%5D.docx?version=1&modificationDate=1552176734000&api=v2
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_download_attachments_102138857_ICANN-2520-2D-2520Memo-2520on-2520thick-2520Whois-255B1-255D.docx-3Fversion-3D1-26modificationDate-3D1552176734000-26api-3Dv2&d=DwMGaQ&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ksGqw06mx_8tgEzKe_n3S7oqAZSXndVQSnz8Y-V60vs&s=EwHaGp_32rcjqSp00faUarwmCiR8S32uNt6tZZM2xw0&e=>
>
>
>
> Summarizing that memo for our purposes, there is a 6.1.f.
> legal basis for thick WHOIS. Full stop. They were neither
> dubious nor ambiguous about it, even by lawyer standards.
>
>
>
> Bird & Bird concluded that there is a legitimate interest,
> the data is necessary for those purposes, and the impact
> to the data subject is negligible. So, they concluded that
> there is a legal basis under 6.1.f.
>
>
>
> The language “provided an appropriate legal basis exists”
> is not necessary because Bird & Bird assures us that a
> legal basis exists.
>
>
>
> *Brian J. King*
> Director of Internet Policy and Industry Affairs, IP Group
>
>
> T +1 443 761 3726
>
> _clarivate.com_
>
> D39D107B
>
>
>
> *From:* IRT.RegDataPolicy
> <irt.regdatapolicy-bounces at icann.org>
> <mailto:irt.regdatapolicy-bounces at icann.org> *On Behalf Of
> *Roger D Carney
> *Sent:* Friday, September 4, 2020 3:38 PM
> *To:* irt.regdatapolicy at icann.org
> <mailto:irt.regdatapolicy at icann.org>
> *Subject:* Re: [IRT.RegDataPolicy] IRT Liaison report on
> Rec7 during the 20Aug2020 GNSO Council Meeting
>
>
>
> Good Afternoon,
>
>
>
> Thanks Alex, no worries about the name, I always blame
> that other Rodger for anything that goes wrong:).
>
>
>
> So, for clarity, you are not against using the language
> from recommendation 7?
>
>
>
> What you are suggesting is adding additional language, is
> that correct?
>
>
>
> I am a bit confused by your assertion that "...without
> agreement that legal basis exists in all cases then the
> IRT explicitly kills Thick WHOIS...". I cannot figure out
> how to connect the dots from "...without agreement that
> legal basis exists in all cases..." to the "...IRT
> explicitly kills Thick WHOIS...", as this has never been
> the case. The Thick WHOIS Policy (all Consensus Policies)
> are always dependent on legal basis and within the Thick
> Policy it even recognized possible conflicts with
> law. Consensus Policy is just one consideration and not
> the deciding consideration, CPs must follow the law and
> then follow Policy as it can within that legal framework.
>
>
>
> I am surprised that the idea that "legal basis exists in
> all cases" is even a thought as this has been known not to
> be true for a long time. Consensus Policy cannot determine
> legal basis and should never strive to, that should be
> purposefully left outside of policy which is why the
> Registration Data Policy cannot state "...legal basis
> exists in all cases...".
>
>
>
> I think we all agree that The Thick WHOIS Policy is a
> Consensus Policy today (even with full implementation yet
> to be realized as final implementation details/actions are
> awaiting "/the GNSO Council makes a determination on
> whether to take action on updates to relevant policies and
> procedures (which could include additional policy work,
> guidance, or other actions to be determined) impacting the
> Thick WHOIS Transition Policy/"). I think we also all
> agree that Phase 1 Recommendations did modify the Thick
> WHOIS Policy but did not overturn it entirely. So, unless
> there is a GNSO Policy Development Process that eliminates
> the Thick WHOIS Policy than all CPs will need to abide by
> that Policy, but obviously in context of their respective
> legal frameworks, which I believe is what the
> Recommendation 7 language correctly allows for and this
> suggested new language does not.
>
>
>
> Have a great weekend (holiday weekend for some), talk to
> you all next week!
>
>
>
>
>
> Thanks
>
> Roger
>
>
>
>
>
> ------------------------------------------------------------------------
>
> *From:*Alex Deacon <alex at colevalleyconsulting.com>
> <mailto:alex at colevalleyconsulting.com>
> *Sent:* Thursday, September 3, 2020 6:35 PM
> *To:* Alex Deacon <alex at colevalleyconsulting.com>
> <mailto:alex at colevalleyconsulting.com>
> *Cc:* Roger D Carney <rcarney at godaddy.com>
> <mailto:rcarney at godaddy.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] IRT Liaison report on
> Rec7 during the 20Aug2020 GNSO Council Meeting
>
>
>
> Notice:This email is from an external sender.
>
>
>
> sorry - Roger, not Rodger!
>
> ___________
>
> *Alex Deacon*
>
> Cole Valley Consulting
>
> alex at colevalleyconsulting.com
> <mailto:alex at colevalleyconsulting.com>
>
> +1.415.488.6009
>
>
>
>
>
>
>
> On Thu, Sep 3, 2020 at 4:30 PM Alex Deacon
> <alex at colevalleyconsulting.com
> <mailto:alex at colevalleyconsulting.com>> wrote:
>
> Rodger,
>
>
>
> Sure - but If we use the language in the
> recommendation ("provided a legal basis exists")
> *without* an indication or agreement that a legal
> basis exists in all cases then the IRT
> explicitly "kills" Thick WHOIS - which is also
> consensus policy approved by the interior community
> including the GNSO and ICANN Board. So....
>
>
>
> Alex
>
>
>
>
>
> ___________
>
> *Alex Deacon*
>
> Cole Valley Consulting
>
> alex at colevalleyconsulting.com
> <mailto:alex at colevalleyconsulting.com>
>
> +1.415.488.6009
>
>
>
>
>
>
>
> On Thu, Sep 3, 2020 at 4:07 PM Roger D Carney
> <rcarney at godaddy.com <mailto:rcarney at godaddy.com>> wrote:
>
> Good Evening,
>
>
>
> Thanks Alex. I agree that some people are over
> thinking this and I believe stepping beyond the
> scope of the IRT.
>
>
>
> I will disagree with you on the "wishy-washy
> language". What I suggested is to use the exact
> wording from the recommendation which was approved
> by the entire community including the GNSO and
> ICANN Board. By using the proposed language from
> staff (and not using the language from the
> recommendation) it is clear that Policy is being
> created outside of the Policy Development Process.
>
>
>
> Can someone provide logic/reasoning why this IRT
> would not use the language from the
> recommendation? The only argument I have heard is
> that some believe that the "...legal basis..."
> already exists. But that is not a reason for
> Policy language modification, that is a reason for
> compliance. Using the language from the
> recommendation does not hinder this compliance
> argument.
>
>
>
> If we remove this language, the IRT has created
> new policy. We have discussed and changed (and
> documented the reasons for the change) other
> recommendation language based on typos,
> unintentional drafting errors, and intent. But it
> is clear that this recommendation is correct in
> language and intent, everyone agrees that
> "...legal basis..." must exist, I have not heard
> anyone argue against that, so once again: Why not
> use the language from the recommendation?
>
>
>
>
>
> Thanks
>
> Roger
>
>
>
>
>
> ------------------------------------------------------------------------
>
> *From:*Alex Deacon <alex at colevalleyconsulting.com
> <mailto:alex at colevalleyconsulting.com>>
> *Sent:* Thursday, September 3, 2020 5:22 PM
> *To:* Roger D Carney <rcarney at godaddy.com
> <mailto:rcarney at godaddy.com>>
> *Cc:* 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] IRT Liaison
> report on Rec7 during the 20Aug2020 GNSO Council
> Meeting
>
>
>
> Notice:This email is from an external sender.
>
>
>
> We seem to be over thinking this - or perhaps
> hoping to find a solution in the
> vague, wishy-washy and
> open-to-broad-interpretation language in the policy.
>
>
>
> As we discussed this all comes down to legal basis.
>
>
>
> Scenario One
>
> · A legal basis exists for the transfer of
> Thick WHOIS data from registrars to registries in
> all cases. This satisfies the "provided an
> appropriate legal basis exists" condition of Rec #7.
>
> · A DPA is drafted that supports and
> details this transfer. This satisfies the "data
> process agreement is in place" clause of Rec #7
>
> · The OneDoc details which data
> elements MUST be transferred.
>
> · Rec #7 is satisfied per policy and the
> Thick WHOIS consensus policy stands. There is no
> impasse/conflict.
>
> Scenario Two
>
> · A legal basis does not exist for the
> transfer of Thick WHOIS data from registrars to
> registries - for any case. The "provided an
> appropriate legal basis exists" condition is not met.
>
> · The IRT has just killed the Thick WHOIS
> consensus policy.
>
> I suppose there may be a Scenario Three where a
> legal basis exists in only some cases. But
> either way this scenario would also kill the Thick
> WHOIS consensus policy.
>
>
>
>
>
> Alex
>
>
>
>
>
> ___________
>
> *Alex Deacon*
>
> Cole Valley Consulting
>
> alex at colevalleyconsulting.com
> <mailto:alex at colevalleyconsulting.com>
>
> +1.415.488.6009
>
>
>
>
>
>
>
> On Wed, Sep 2, 2020 at 10:40 AM Roger D Carney
> <rcarney at godaddy.com <mailto:rcarney at godaddy.com>>
> wrote:
>
> Good Afternoon,
>
>
>
> Sorry, I thought I had sent this a while back
> and just found it in my drafts.
>
>
>
> I have been thinking more about this over the
> past few weeks (since our meeting with the
> Board and gaining additional insight into
> their thinking) and I would like to suggest
> taking Marc's point a little further and more
> direct. If we go back to what I believe was
> the original language in the OneDoc (and the
> language that is in the Final Report) and state:
>
>
>
> These elements MUST be transferred:
>
> Domain Name
> Registrar Whois Server
> Registrar URL
> Registrar
> Registrar IANA ID
> Registrar Abuse Contact Email
> Registrar Abuse Contact Phone
> Domain Status(es)
>
> These elements MUST be transferred, if
> collected or generated:
>
> Name Server(s)
> Name Server IP Address(es)
>
> These elements MUST be transferred provided an
> appropriate legal basis exists and data
> processing agreement is in place:
>
> Registrant Name
> Registrant Street
> Registrant City
> Registrant Country
> Registrant Phone
> Registrant Email
>
> These elements MUST be transferred provided an
> appropriate legal basis exists and data
> processing agreement is in place, if collected
> or generated:
>
> Registrant Organization
> Registrant State/province
> Registrant Postal code
> Registrant Phone ext
> Registrant Fax
> Registrant Fax ext
> Tech Name
> Tech Phone
> Tech Email
>
> These elements MAY be transferred:
>
> Registrar Registration Expiration Date
> Reseller
>
> Hopefully, I didn't miss anything.
>
>
>
> This is exactly what the recommendation states
> and I believe this is what everyone in this
> group is saying. I believe the only difference
> within the group is that some believe that "an
> appropriate legal basis" already exists, and
> others believe that this needs to be
> determined ongoing by ICANN Compliance and the
> respective contracted parties. The interesting
> thing to me is, that no matter which side of
> this difference you are on, using the
> recommendation language works to your end.
>
>
>
> This IRT does not have the responsibility nor
> the ability, of globally determining that
> "appropriate legal basis exists". As Marc
> points out this is bigger than Consensus
> Policies and Contracts, and this cannot be
> codified in Policy and must be left to ICANN
> Compliance and the contracted party.
>
>
>
> As nice as it would be to create a simple
> Policy statement for this issue, I do not
> believe that is possible. The Phase 1 team
> purposely crafted this language and I see no
> logical reason for this IRT to change that
> language, again it seems like everyone (Phase
> 1, IRT/IPT, Board, Council) agrees the
> language is correct so let's use it and leave
> "legal" determinations up to those that are
> legally responsible.
>
>
>
>
>
> Thanks
>
> Roger
>
>
>
>
>
> ------------------------------------------------------------------------
>
> *From:*IRT.RegDataPolicy
> <irt.regdatapolicy-bounces at icann.org
> <mailto:irt.regdatapolicy-bounces at icann.org>>
> on behalf of Sebastien at registry.godaddy
> <mailto:Sebastien at registry.godaddy>
> <Sebastien at registry.godaddy>
> <mailto:Sebastien at registry.godaddy>
> *Sent:* Wednesday, August 26, 2020 2:42 AM
> *To:* Anderson, Marc <mcanderson at verisign.com
> <mailto:mcanderson at verisign.com>>;
> swyld at tucows.com <mailto:swyld at tucows.com>
> <swyld at tucows.com <mailto:swyld at tucows.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] IRT Liaison
> report on Rec7 during the 20Aug2020 GNSO
> Council Meeting
>
>
>
> Notice:This email is from an external sender.
>
>
>
> Hi Marc, Sarah and Team,
>
>
>
> I fully appreciate your points and concerns.
>
> I can’t speak to what the Council sees as its
> own remit on this matter, but I agree that it
> is not by itself able to pass legal judgement,
> it would need to rely on advice.
>
>
>
> This said, I reported on Thursday verbally to
> the Council that a question would be posed on
> the matter of Legal Basis, on instructions
> from this group given to me, equally verbally,
> on Wednesday.
>
> I also promised the Council a written
> statement containing the said question.
>
>
>
> My reports to the Council are my
> responsibility only, but this is effectively
> the second report I give in a row which is
> subsequently disavowed by one party or another.
>
> A month ago I reported that we were close to a
> consensus on going back to the recommendation
> wording because I had obtained that
> understanding from the different members of
> the IRT with whom I interacted.
>
>
>
> For the credibility of this process, and in
> part for my own, I will ask going forward that
> liaison reports be drafted and approved by the
> team in writing.
>
> Further and in the interest of time, I suggest
> that either we are able to agree on an
> appropriate answer to the Council in the
> coming 10 days (halfway to the next Council
> meeting), or I will need to go back to it with
> the fact that the IRT is indeed at an impasse.
>
> This answer may be based on the “path forward”
> document if we can obtain consensus on it, on
> the Legal Basis question if that is the
> pre-requisite, it can also be based on any
> third option the group sees fit; but we do
> need to come back to the Council with something.
>
>
>
> In June the Council resolved to ask the IRT
> via its liaison if indeed there was an issue
> with Recommendation 7 which required Council’s
> assistance to resolve.
>
> We will have taken the better part of 3 months
> to come to this conclusion, but if we are not
> able to resolve this as the IRT, it is my
> responsibility to come back to the Council
> with that answer.
>
>
>
>
>
> I remain of course open to all suggestions,
> offered on this list or via any other channel.
>
>
>
> Kindly,
>
>
>
>
>
>
>
> *Sebastien Ducos*
>
> GoDaddy Registry | Senior Client Services Manager
>
> Image removed by sender. signature_2061024682
>
> +61449623491
>
> Level 8, 10 Queens Road
>
> Melbourne, VIC, Australia
>
> 3004
>
>
> sebastien at registry.godaddy
> <mailto:sebastien at registry.godaddy>
>
> www.linkedin.com/in/sebastienducos
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.linkedin.com_in_sebastienducos&d=DwMF-g&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ddb2R34v_iarUT2F1OWXjsfV9xL0QTRwXYgakb2v-z4&s=ZxAHO1cWP390CIU2OK2YaBqAfTLKq0C7IzkgHDMNZCk&e=>
>
>
>
>
>
> *From: *"Anderson, Marc"
> <mcanderson at verisign.com
> <mailto:mcanderson at verisign.com>>
> *Date: *Wednesday, 26 August 2020 at 12:16 am
> *To: *Sebastien Ducos
> <Sebastien at registry.godaddy>
> <mailto:Sebastien at registry.godaddy>,
> "swyld at tucows.com <mailto:swyld at tucows.com>"
> <swyld at tucows.com <mailto:swyld at tucows.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] IRT Liaison
> report on Rec7 during the 20Aug2020 GNSO
> Council Meeting
>
>
>
> Notice:This email is from an external sender.
>
>
>
> Hi Sebastien,
>
>
>
> Thank you for circulating this draft and for
> the ongoing work to resolve the Rec 7 issue. I
> can understand your thinking behind trying to
> get an answer from the Council that can help
> resolve the disagreement, but I don’t believe
> the question you’ve posed is the best one to
> ask, or even an appropriate question to put to
> the Council.
>
>
>
> First off, I share Sarah’s concerns that the
> question as written is beyond the scope of the
> Council. We cannot ask the Council to make a
> legal judgment for the Contracted Parties. The
> Council’s role is to manage the policy
> development process, not adjudicate how those
> policies apply to and are enforced with
> Contracted Parties. That’s very squarely the
> job of ICANN’s Compliance Department.
>
>
>
> Moreover, my recollection of developing this
> recommendation during Phase 1 is that the
> reference to a “legal basis” was not intended
> to refer ONLY to ICANN Consensus Policies. So
> again, it becomes inappropriate to ask the
> Council to make a determination as to whether
> a legal basis does indeed exist for the
> transfer of all data in all cases. As I
> mentioned during the call on Wednesday, if
> that had been the intended outcome of the
> Phase 1 deliberations, then that is what the
> policy recommendation would reflect. But
> that’s not what the Phase 1 WG concluded –
> instead, it concluded that the transfer of
> certain data elements would be optional.
>
>
>
> Rather than posing this question to Council, I
> think it makes much more sense to go back to
> your original plan and send them your written
> analysis document. The fundamental question
> here is how Rec 7 should be reflected in the
> Consensus Policy. That should have a
> straightforward answer. But we keep getting
> caught up in trying to interpret or preempt
> how the policy will later be enforced, and
> that’s not what either the IRT or the Council
> is here to do. So I think it makes sense to
> refocus our question to Council on how the
> recommendation should be implemented, as you
> describe in your paper.
>
>
>
> Best,
>
> Marc
>
>
>
>
>
> *From:*IRT.RegDataPolicy
> <irt.regdatapolicy-bounces at icann.org
> <mailto:irt.regdatapolicy-bounces at icann.org>>
> *On Behalf Of *Sebastien at registry.godaddy
> <mailto:Sebastien at registry.godaddy>
> *Sent:* Monday, August 24, 2020 12:42 PM
> *To:* Sarah Wyld <swyld at tucows.com
> <mailto:swyld at tucows.com>>;
> irt.regdatapolicy at icann.org
> <mailto:irt.regdatapolicy at icann.org>
> *Subject:* [EXTERNAL] Re: [IRT.RegDataPolicy]
> IRT Liaison report on Rec7 during the
> 20Aug2020 GNSO Council Meeting
>
>
>
> Hi Sarah,
>
>
>
> In my view this replaces my earlier "suggested
> path to resolution" document for now.
>
> I believe that depending on the answer to this
> question we may or not be able to resolve Rec 7.
>
> If the Council’s answer to this doesn’t help
> us resolve Rec 7, we will then review the
> previous document in light of the answer and
> send that too.
>
>
>
> I got an acknowledgment of reception on our
> Rec 12 question but no answer so far. I will
> chase it.
>
>
>
> Kindly,
>
>
>
>
>
>
>
> *Sebastien Ducos*
>
> GoDaddy Registry | Senior Client Services Manager
>
> Image removed by sender. signature_1571866922
>
> +61449623491
>
> Level 8, 10 Queens Road
>
> Melbourne, VIC, Australia
>
> 3004
>
>
> sebastien at registry.godaddy
> <mailto:sebastien at registry.godaddy>
>
> www.linkedin.com/in/sebastienducos
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.linkedin.com_in_sebastienducos&d=DwMF-g&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=ddb2R34v_iarUT2F1OWXjsfV9xL0QTRwXYgakb2v-z4&s=ZxAHO1cWP390CIU2OK2YaBqAfTLKq0C7IzkgHDMNZCk&e=>
>
>
>
>
>
> *From: *"IRT.RegDataPolicy"
> <irt.regdatapolicy-bounces at icann.org
> <mailto:irt.regdatapolicy-bounces at icann.org>>
> on behalf of Sarah Wyld <swyld at tucows.com
> <mailto:swyld at tucows.com>>
> *Organisation: *Tucows
> *Date: *Monday, 24 August 2020 at 6:30 pm
> *To: *"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] IRT Liaison
> report on Rec7 during the 20Aug2020 GNSO
> Council Meeting
>
>
>
> Notice:This email is from an external sender.
>
>
>
> Hi Sebastien,
>
> Thank you for sharing this on the list.
>
> How does this request below relate to your
> "suggested path to resolution" document, are
> they both being provided to the Council? I
> notice that the question to Council at the end
> of the letter in this thread below is
> different from the conclusion you reached in
> the document, and the question below would
> lead the GNSO Council to provide legal
> guidance to the Contracted Parties, was that
> your intent?
>
> And a separate question, but since I'm already
> writing -- I think you were going to ask the
> Council for an update on the consultation
> between the ICANN Board and GNSO Council on
> the portions of Rec #12 not adopted by the
> Board. Do you have any further info for us on
> this topic?
>
> Thank you,
>
> Sarah W
>
>
>
>
>
>
>
> --
>
> Sarah Wyld
>
> Domains Product Team
>
> Tucows
>
> +1.416 535 0123 Ext. 1392
>
>
>
> On 8/21/2020 6:15 PM, Ducos, Sebastien via
> IRT.RegDataPolicy wrote:
>
> Dear IRT,
>
>
>
> As per our discussion during our IRT call
> on 19Aug2020, I reported yesterday
> (20Aug2020) to the GNSO Council the IRT’s
> request for clarification on the prior
> existence of a Legal Basis to support the
> transfer of data under Rec 7.
>
>
>
> For clarity, I now have to present the
> said request in writing. I propose the
> following wording, but invite your input.
>
> As has been the case all along in this
> exercise, this is not a reflexion of my
> personal point of view, but should
> represent the different points of view of
> the IRT. Please ensure yours is reflected.
>
>
>
> For the sake of council members who may
> not all be as familiar with the topic as
> we are, I would like to submit a limited
> relevant number of reference documents for
> their review.
>
> Please confirm that the ones I have
> included are indeed relevant and the links
> I have provided are the most direct to the
> latest/final versions of the said documents.
>
>
>
>
>
>
>
> [Date]
>
> RE: EPDP Phase 1 Recommendation 7 – Legal
> Basis
>
>
>
> Dear GNSO Council,
>
>
>
> In an attempt to resolve a different in
> interpretation of the EPDP Phase I
> Recommendation 7, the IRT is seeking
> clarification with regards to the
> existence of legal basis which covers the
> transfer of data (including personal data)
> from Registrars to Registries, in all cases.
>
>
>
> Recommendation 7 states:
>
> /“The EPDP Team recommends that the
> specifically-identified data elements
> under “[t]ransmission of registration data
> from Registrar to Registry”, as
> illustrated in the aggregate data elements
> workbooks, must be transferred from
> registrar to registry provided an
> appropriate legal basis exists and data
> processing agreement is in place. In the
> aggregate, these data elements are:”/
>
> / /
>
> [followed by the list of data points that
> may be transferred, some marked as
> Mandatory (The domain name, fields
> pertaining to the Registrar and Domain
> Statuses), others as Optional (contact
> fields, name servers, Registrar expiry
> date and Reseller)]
>
> Ref: https://gnso.icann.org/sites/default/files/file/field-file-attach/epdp-gtld-registration-data-specs-final-20feb19-en.pdf
> <https://urldefense.com/v3/__https:/gnso.icann.org/sites/default/files/file/field-file-attach/epdp-gtld-registration-data-specs-final-20feb19-en.pdf__;!!N14HnBHF!sCWU7y9IbaKHs6GMHTcYVyVtmbssBSq1aPdTMDjtwrN2EavylO7yn8IgebUbvTovu3GBdw$>
>
>
>
>
>
> The IRT remains divided in the
> interpretation of the mention “/provided
> an appropriate legal basis exists and data
> processing agreement is in place/” with:
>
> * Parties who consider the mention key
> as in their view a legal basis may not
> exist in all cases and must be
> established for each TLD,
> * Parties who consider the mention
> relevant, view the legal basis as
> pre-established under Consensus Policy
> and expect that the currently
> negotiated data processing agreement
> (between ICANN and the CPH) will
> reflect the said legal basis,
> * Parties who consider legal basis
> established in all cases in this
> context, and seek to remove the
> sentence for the avoidance of confusion.
>
>
>
>
>
> Further, each party cites in its argument:
>
> * The EPDP Phase I Final Report and the
> underlying work
> - https://gnso.icann.org/sites/default/files/file/field-file-attach/epdp-gtld-registration-data-specs-final-20feb19-en.pdf
> <https://urldefense.com/v3/__https:/gnso.icann.org/sites/default/files/file/field-file-attach/epdp-gtld-registration-data-specs-final-20feb19-en.pdf__;!!N14HnBHF!sCWU7y9IbaKHs6GMHTcYVyVtmbssBSq1aPdTMDjtwrN2EavylO7yn8IgebUbvTovu3GBdw$>
> * Existing Consensus Policy including
> but not limited to the Thick RDDS
> (WHOIS) Transition Policy
> - https://www.icann.org/resources/pages/thick-whois-transition-policy-2017-02-01-en
> <https://urldefense.com/v3/__https:/www.icann.org/resources/pages/thick-whois-transition-policy-2017-02-01-en__;!!N14HnBHF!sCWU7y9IbaKHs6GMHTcYVyVtmbssBSq1aPdTMDjtwrN2EavylO7yn8IgebUbvTomhXpJgw$>
> * The “Bird & Bird memo” of 8 March 2019
> “Advice on the legal basis for
> transferring Thick WHOIS”
> - https://community.icann.org/download/attachments/102138857/ICANN%20-%20Memo%20on%20thick%20Whois%5B1%5D.docx?version=1&modificationDate=1552176734000&api=v2
> <https://urldefense.com/v3/__https:/community.icann.org/download/attachments/102138857/ICANN*20-*20Memo*20on*20thick*20Whois*5B1*5D.docx?version=1&modificationDate=1552176734000&api=v2__;JSUlJSUlJQ!!N14HnBHF!sCWU7y9IbaKHs6GMHTcYVyVtmbssBSq1aPdTMDjtwrN2EavylO7yn8IgebUbvTpLToewLQ$>
>
> and related public comments submitted in
> the context of the above.
>
>
>
>
>
> Question to the GNSO Council:
>
> * Does the GNSO Council advise that
> there exists under Consensus Policy
> and in accordance with GDPR a legal
> basis which covers the transfer of
> data, including personal data, between
> Registrar and Registries in all cases?
>
>
>
>
>
> [IRT Liaison signature]
>
>
>
>
>
>
>
> Kindly,
>
>
>
>
>
>
>
> *Sebastien Ducos*
>
> GoDaddy Registry | Senior Client Services
> Manager
>
> *Error! Filename not specified.*
>
> +61449623491
>
> Level 8, 10 Queens Road
>
> Melbourne, VIC, Australia
>
> 3004
>
>
> sebastien at registry.godaddy
> <mailto:sebastien at registry.godaddy>
>
> www.linkedin.com/in/sebastienducos
> <https://urldefense.com/v3/__https:/www.linkedin.com/in/sebastienducos__;!!N14HnBHF!sCWU7y9IbaKHs6GMHTcYVyVtmbssBSq1aPdTMDjtwrN2EavylO7yn8IgebUbvTpZ-jSKMQ$>
>
>
>
>
>
>
>
> _______________________________________________
>
> IRT.RegDataPolicy mailing list
>
> IRT.RegDataPolicy at icann.org
> <mailto:IRT.RegDataPolicy at icann.org>
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>
>
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Subject: Re: [IRT.RegDataPolicy] IRT Liaison report on Rec7 during the 20Aug2020 GNSO Council Meeting
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