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

Crystal Ondo ondo at google.com
Wed Aug 10 20:23:33 UTC 2022


Thank you, Catherine and RrSG members.

@ICANN - please let me know when / how this will be formally approved so we
can plan to update our registrars accordingly.

Best,
Crystal


On Wed, Aug 10, 2022 at 1:05 PM Catherine Merdinger
<catherine at identity.digital> wrote:

> Crystal and ICANN,
>
> Thank you for your patience given our email issues.  The RrSG has no
> further concerns with the updates Google has made and suggests ICANN
> approve the RRA as updated.
>
> Please let me know if you need anything from the RrSG to close this out.
> Catherine
> *Catherine Merdinger **| *Corporate Counsel *| Identity Digital *Inc. *|*
> +1.319.541.9416 <(319)%20541-9416> *| *she/her
>
>
>
> On Wed, Aug 3, 2022 at 10:11 AM Catherine Merdinger
> <catherine at identity.digital> wrote:
>
>> 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 <(319)%20541-9416> *| *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
>>>
>>

-- 

Crystal Ondo

*Operations & Policy Lead*

Google Domains & Registry

ondo at google.com
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