[IRT.RegDataPolicy] IRT Task 136 Review Drafting Error in Section 5of the Public Comment form 20210323
Sarah Wyld
swyld at tucows.com
Mon Mar 15 15:04:42 UTC 2021
Hi Dennis,
I have attempted to review these drafting errors both on my own and with the help of the CPH members of the IRT team, but in some cases I am having a hard time understanding exactly what the change is.
Would it be possible for the IPT to update the Drafting Errors section of the doc to clearly include (a) text from the Final Report, (b) text from the OneDoc, and (c) rationale for the change/difference?
Specifically for the one labelled “Section 12.1.1: Registrant and Tech emails. Final report only includes log files.” I am not clear what change is being described here, and I don’t see how the rationale matches the subject. In the rationale, there are some bits that seem to be inapplicable (e.g. Policy language assumes a legal basis exists and data processing agreement is in place; Board Resolution states Thick WHOIS Policy is not repealed or overturned) and other parts that seem more relevant but don’t seem to match the subject (“in order to create a technical contact over EPP, Tech Name and Tech email fields are required. Therefore, the draft policy language clarifies that BOTH tech fields MUST be collected if offered and provided.”)
Thanks.
--
Sarah Wyld, CIPP/E
Policy & Privacy Manager
Tucows
swyld at tucows.com
+1.416 535 0123 Ext. 1392
From: Dennis Chang via IRT.RegDataPolicy
Sent: March 9, 2021 4:24 PM
To: Dennis Chang via IRT.RegDataPolicy
Subject: [IRT.RegDataPolicy] IRT Task 136 Review Drafting Error in Section 5of the Public Comment form 20210323
Dear IRT,
The subject of what we call “Drafting Error” is an important one as we draft our policy language to be deliberately inconsistent with the recommendation. We’ll discuss this briefly tomorrow and leave you to review and comment.
136
Review Drafting Error in Section 5 of the Public Comment form
20210323
--
Kind Regards,
Dennis S. Chang
GDD Programs Director
Phone: +1 213 293 7889
Sykpe: dennisSchang
www.icann.org One World – One Internet
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