[RRA] [Ext] Re: RRA Amendment Notification for Multiple (46) TLDs | Charleston Road Registry Inc. [ ref:_00D616tJk._5004Ms9IBw:ref ]

Catherine Merdinger catherine at identity.digital
Wed Aug 3 17:11:26 UTC 2022


Crystal,

Thank you for this.  Unfortunately, the RrSG has been having some trouble
with its emails, so when I forwarded your response to the list, it seems it
didn't go through.  I believe it is now through to the whole list and we
will work to get our final approval or further comments back to you ASAP.

My apologies for the delay.
Catherine
*Catherine Merdinger **| *Corporate Counsel *| Identity Digital *Inc. *|*
+1.319.541.9416 *| *she/her



On Thu, Jul 28, 2022 at 7:39 AM Crystal Ondo <ondo at google.com> wrote:

> ICANN and RrSG RRA Amendment Team Members,
>
> Below are responses to the RrSG questions.
>
>
> #1-4: Yes, Google Registry is aware of the UK's IDTA. The RRA Section 12.9
> includes: "Registry Operator may revise any URLs noted herein from time to
> time in its sole discretion upon notice to Registrar." Google is tracking
> changes in data protection laws, will amend the links and references in
> accordance with such changes, and provide notice to the Registrars, or
> amend the RRA, accordingly.
>
> #5: We agree and have updated the section references in the attached.
>
> Documents attached:
>
>    - Redline against original RRA.
>    - Redline against previously proposed RRA.
>    - Clean document.
>
> Please let me know if you have any additional questions.
>
> Crystal
>
>
>
> On Tue, Jul 12, 2022 at 3:35 PM Crystal Ondo <ondo at google.com> wrote:
>
>> ICANN and RrSG,
>>
>> Acknowledging receipt of this email. Google Registry is working to get
>> answers to the RrSG points and will respond directly.
>>
>> Crystal
>>
>>
>> On Tue, Jul 12, 2022 at 2:55 PM Camia Frank <camia.frank at icann.org>
>> wrote:
>>
>>> Dear Catherine and All,
>>>
>>>
>>>
>>> Thank you to the RrSG for providing the feedback. We did receive both
>>> emails, and we will make the necessary adjustments moving forward. To
>>> continue this discussion, the registry operator is copied on this thread
>>> and can directly respond to the RrSG with any questions, clarifications, or
>>> suggested modifications to the proposed amendments to address the points
>>> raised.
>>>
>>>
>>>
>>> Warm Regards,
>>>
>>>
>>>
>>> Camia Frank
>>>
>>> GDS Service Delivery
>>>
>>>
>>>
>>> *From: *Catherine Merdinger <catherine at identity.digital>
>>> *Date: *Tuesday, July 5, 2022 at 1:17 PM
>>> *To: *ICANN Global Support Center <globalsupport at icann.org>
>>> *Cc: *"secretariat at icannregistrars.org" <secretariat at icannregistrars.org>,
>>> "rra at icann.org" <rra at icann.org>, "aheineman at godaddy.com" <
>>> aheineman at godaddy.com>, Andee Hill <andee.hill at icann.org>, Amanda
>>> Fessenden <amanda.fessenden at icann.org>, Jeanne Gregg <
>>> jeanne.gregg at icann.org>, Morgan Govaars <morgan.govaars at icann.org>,
>>> Danielle Gordon <danielle.gordon at icann.org>, Camia Frank <
>>> camia.frank at icann.org>, Maritza Alarcon <maritza.alarcon at icann.org>, "
>>> ondo at google.com" <ondo at google.com>
>>> *Subject: *[Ext] Re: RRA Amendment Notification for Multiple (46) TLDs
>>> | Charleston Road Registry Inc. [ ref:_00D616tJk._5004Ms9IBw:ref ]
>>>
>>>
>>>
>>> ICANN and Google,
>>>
>>>
>>>
>>> Thank you for the opportunity to review the redlined DPA for the Google
>>> TLDs.  The RrSG has two points of substantive feedback and one note where
>>> we believe there to be a typographical error.  You will find the specific
>>> questions for Google below, but primarily the request is to incorporate the
>>> UK SCCs (apparently now the UK IDTA) for registrars, where applicable.  We
>>> understand that the Temporary Specification DPA text does not include a
>>> reference to the UK SCCs/IDTA, but as events have evolved, we'd ask the
>>> registries consider including them going forward.
>>>
>>>
>>>
>>> Google folks - please let me know if you think it would be helpful to
>>> talk any of the questions below through or if you are comfortable making
>>> the requested changes without further conversation.
>>>
>>>
>>>
>>> 1.       Are Google aware of the UK’s IDTA, which effectively
>>> replaced/replaces the UK SCCs?
>>>
>>> 2.       Are they aware of the 21 September 2022 deadline for using the
>>> UK SCCs after which the IDTA must be used to ensure appropriate safeguards
>>> for UK to US data transfers?
>>>
>>> 3.       If yes to the above, would it make sense to try and
>>> incorporate the UK IDTA into the DPA in some form now to future-proof the
>>> DPA and save Google from amending and the RRA Team re-reviewing the RRA
>>> from 22 September onwards? This can be done similar to how they have
>>> incorporated the EU SCCs and UK SCCs.
>>>
>>> 4.       To assist with future proofing, we would ask if Google would
>>> be willing to consider adding “or their successors” to Sections 2 (d) and
>>> (n)?
>>>
>>> 5.       References in Section 5 (a) (ii.) and (iii.) need to be
>>> updated – both Sections refer to Section 5 (b)(i) but it appears this
>>> should be updated to Section 5 (a)(i).
>>>
>>>
>>>
>>> Thank you,
>>>
>>> Catherine
>>>
>>> *Catherine Merdinger **|* Corporate Counsel *| Identity Digital *Inc.
>>> *|* +1.319.541.9416 <(319)%20541-9416> *|* she/her
>>>
>>>
>>>
>>>
>>>
>>> On Mon, Jun 6, 2022 at 5:19 PM Catherine Merdinger
>>> <catherine at donuts.email> wrote:
>>>
>>> ICANN,
>>>
>>>
>>>
>>> I can confirm receipt on behalf of the RrSG.  However, noting the
>>> upcoming ICANN meeting, we would like to prospectively request a one-week
>>> extension for our review, for a new response deadline of July 5, 2022
>>> (noting the July 4 holiday in the US).  Please let me know if this is
>>> acceptable to you.
>>>
>>>
>>>
>>> Thanks,
>>>
>>> Catherine
>>>
>>> *Catherine Merdinger **| *Corporate Counsel *| *Donuts Inc. *|*
>>> +1.319.541.9416 <(319)%20541-9416> *| *she/her
>>>
>>>
>>>
>>>
>>>
>>> On Mon, Jun 6, 2022 at 5:11 PM ICANN Global Support Center <
>>> globalsupport at icann.org> wrote:
>>>
>>> Hello Ashley,
>>>
>>> Attached, please find the cover letter and the red-lined RRA Amendment
>>> for multiple (46) TLDs submitted by Charleston Road Registry Inc. to be
>>> shared with your Stakeholder Group:
>>>
>>> As indicated in their cover letter, Charleston Road Registry Inc. has
>>> shared a separate amendment (which they have labeled as “RRA SCC Data
>>> Processing Addendum Amendment”) of how they will incorporate the proposed
>>> changes with existing registrars. We are including this amendment for the
>>> RrSG’s consideration in its review.
>>>
>>> Please respond by 23:59 UTC on *Monday, 27 June 2022* to let us know if
>>> your Stakeholder Group has concerns, does not have concerns, or if
>>> additional review time is required. If the Stakeholder Group has concerns,
>>> ICANN org will continue with the next step of the RRA Amendment Procedure,
>>> which is to consult with the RrSG and the Registry Operator to attempt to
>>> resolve any such concerns.
>>>
>>> Warm Regards,
>>>
>>> Camia Frank
>>> GDS Service Delivery[image: Image removed by sender.]
>>>
>>> ref:_00D616tJk._5004Ms9IBw:ref
>>>
>>>
>>
>> --
>>
>> Crystal Ondo
>>
>> *Operations & Policy Lead*
>>
>> Google Domains & Registry
>>
>> ondo at google.com
>>
>
>
> --
>
> Crystal Ondo
>
> *Operations & Policy Lead*
>
> Google Domains & Registry
>
> ondo at google.com
>
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