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

[Catherine Merdinger]

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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