closed EPDP Phase 2A Policy Recommendations for ICANN Board Consideration
During this Public Comment proceeding, seven organizations and groups provided comments on the EPDP Phase 2A Final Report. In addition to this summary, the full text of the comments will be transmitted to the ICANN Board for its consideration prior to its vote on the EPDP Phase 2A recommendations.
The ICANN Board values the opportunity to receive comments from the ICANN Community and thanks those who participated in this proceeding.
What We Received Input On
The ICANN Board will soon consider the EPDP Phase 2A Final Report, which includes four policy recommendations. Prior to the Board’s consideration of this Final Report, ICANN org is seeking input on the EPDP Team’s Phase 2A recommendations, which relate to the topics of 1) the differentiation of legal vs. natural persons' registration data and 2) the feasibility of unique contacts to have a uniform anonymized email address.
An abbreviated version of the four recommendations is provided below:
- A field or fields MUST be created to facilitate differentiation between legal and natural person registration data and/or if that registration data contains personal or non-personal data.
- Contracted Parties who choose to differentiate based on person type SHOULD follow the guidance included in the report.
- If a GDPR Code of Conduct is developed, the guidance to facilitate differentiation between legal and natural person data SHOULD be considered within ICANN by the relevant controllers and processors.
- Contracted Parties who choose to publish a registrant-based or registration-based email address in the publicly accessible RDDS should evaluate the legal guidance obtained by the EPDP Team on this topic.
ICANN Board is now welcoming input on the four recommendations from the EPDP Phase 2A Final Report. Per the Bylaw requirements, the ICANN Board will consider whether or not these recommendations are in the best interests of the ICANN community and ICANN org.
|Proposals For Your Input|
On 17 May 2018, the ICANN Board approved the Temporary Specification for generic top-level domain (gTLD) Registration Data to allow contracted parties to comply with existing ICANN contractual requirements while also complying with the European Union's General Data Protection Regulation (GDPR). This Board action triggered the GNSO Council initiation of the Policy Development Process (PDP) on 19 July 2018. The PDP was conducted in two phases: Phase 1 was chartered to confirm, or not, the Temporary Specification by 25 May 2019; Phase 2 was chartered to discuss, among other elements, a standardized access model to nonpublic registration data (SSAD).
The GNSO Council adopted the Final Report for Phase 2 during its meeting on 24 September 2020; however, in response to a request from some EPDP Team members, the GNSO Council asked the EPDP Team to continue work on two topics: 1) the differentiation of legal vs. natural persons' registration data and 2) the feasibility of unique contacts to have a uniform anonymized email address. These two topics constituted the focus of Phase 2A.
The GNSO Council approved the Phase 2A Final Report on 27 October 2021.