[RDS-WHOIS2-RT] 5.1 Edits

[Jackie Treiber]

Recommendation 5.1 Re-write:

The ICANN Board should direct the ICANN Organization to take every reasonable measure to ensure "that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay" (GDPR, art. 5(1)(d), and to take the necessary steps to identify inaccuracies, both for standard registrations and those that are made through P/P services. For example, it could look for potentially-anomalous ARS results1 to determine the underlying cause and take appropriate action to reduce anomalies. If the ARS program were to be discontinued, measures to the same effect should be implemented for the subsequent program for data quality assurance.


1(e.g., 40% of ARS-generated tickets closed with no action because the RDS (WHOIS) record changed between the time the ARS report was generated and the time the registration was reviewed by ICANN Contractual Compliance)


Rationale:

According to the GDPR, Article 5, paragraph 1, litera D, "Accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay ('accuracy').


The focus should be not only the contactability, but also the reliability (corresponding to the Registrant). It's highly recommended to have a measurement on the improvement on an annual basis.




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