Public Comment on the RDRS Policy Alignment Analysis by Remmy Nweke

Date: December 12, 2025

To: The ICANN Community and the Policy Alignment Analysis Team

From: Remmy Nweke (ICT Journalist, Consultant, and Digital Rights Advocate, Nigeria/Africa Focus)

Subject: Ensuring Predictability and Equity for the Global South in the Registration Data Request Service (RDRS) Policy

I commend the ICANN community for extending the deadline and undertaking the critical work of defining a clear path toward a predictable and scalable model for the future of nonpublic gTLD registration data disclosure via the RDRS. Community perspectives are indeed essential, and my comment is offered from the vantage point of the African ICT sector, focusing on policy alignment, digital rights, and enforcement needs in emerging economies.

1. Prioritizing Predictability and Local Enforcement Needs

For law enforcement, consumer protection agencies, and media organizations in developing nations, access to nonpublic registration data is crucial for combating localized cybercrime (e.g., domain abuse, phishing, romance scams, and fraud targeting local populations). The current system often lacks transparency and consistency, which delays justice.

Recommendation: The RDRS policy must establish clear, objective, and globally consistent criteria for disclosure. Crucially, the definition of "Legitimate Interest" must be explicitly inclusive of essential local regulatory, journalistic due diligence, and consumer protection needs pursued by entities that may not possess the litigation resources of global corporations. Without this predictability, the RDRS risks becoming a tool primarily accessible to the few, not the many.

2. Upholding Digital Rights through Data Minimization

In the African context, building public trust in the internet's infrastructure is paramount for advancing digital inclusion. Over-disclosure or misuse of registration data poses a direct threat to this trust and to the fundamental digital rights of registrants.

Recommendation: I strongly urge the Policy Alignment Analysis to enforce rigorous Data Minimization principles. Disclosure must be strictly limited to only the data necessary to satisfy the demonstrably legitimate purpose of the request. Furthermore, the final policy must guarantee a robust, timely, and transparent notification mechanism for any affected registrant whose nonpublic data is disclosed, presented in a format that is linguistically and contextually appropriate for a global user base.

3. Operational Equity for Regional Implementers

The technical solution must be scalable not only globally but also practically for all players, especially African-based registrars and registries who often operate with limited resources and face unique infrastructure challenges.

Recommendation: The policy framework should prioritize technical implementations that are cost-effective, simple to integrate, and sustainable for smaller, regional actors. Care must be taken to avoid creating overly complex operational burdens that could inadvertently disadvantage or deter the growth of the domain name industry in the Global South.

Conclusion

The RDRS presents a vital opportunity to define a responsible, scalable framework. My contribution aims to ensure that this framework serves all stakeholders equitably. The policy's ultimate success will be measured by its ability to deliver predictable access for legitimate enforcement purposes while simultaneously enshrining the privacy and trust of internet users worldwide, particularly those in underserved communities.

Thank you for the opportunity to provide this essential community perspective.

Overall Position: The submission strongly advocates for an RDRS policy framework that is globally equitable, predictable, and scalable while firmly embedding digital rights and considering the resource constraints and specific enforcement needs of the Global South, particularly Africa.

High-Level Observations & Recommendations:

Predictability and Enforcement: The RDRS must establish clear, low-barrier, and consistent disclosure criteria to effectively support local law enforcement, consumer protection, and journalistic due diligence efforts against cybercrime in emerging economies. The definition of "Legitimate Interest" must be explicitly inclusive of these regional needs.

Digital Rights and Privacy: The policy must prioritize rigorous Data Minimization principles and mandate a robust, transparent, and linguistically appropriate notification mechanism for all registrants whose nonpublic data is disclosed to uphold fundamental digital rights and maintain public trust.

Operational Equity: The technical implementation must be cost-effective and simple to integrate for African-based registrars and registries to ensure compliance without placing undue operational burden on resource-constrained regional implementers.