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

Catherine Merdinger catherine at donuts.email
Tue Jul 5 20:20:57 UTC 2022


Hi again,

I'm resending the RrSG response because I got an error from the
rra at icann.org list because my new email address (catherine at identity.digital)
isn't able to post to that list.  If someone at ICANN could please add my
new email address to that list (feel free to drop the donuts.email
address), that would be wonderful!  Thanks.

Find the response from the RrSG below - perhaps for the second time.
*Catherine Merdinger **| *Corporate Counsel *| Identity Digital *Inc. *|*
+1.319.541.9416 *| *she/her



On Tue, Jul 5, 2022 at 1:17 PM Catherine Merdinger
<catherine at identity.digital> wrote:

> 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 *| *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 *| *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
>>>
>>> ref:_00D616tJk._5004Ms9IBw:ref
>>>
>>
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