Today, the ICANN org sent to the European Data Protection Board (EDPB) a paper, "Exploring a Unified Access Model for gTLD Registration Data," which outlines a proposed Unified Access Model (UAM) based on the Technical Study Group's technical model. The model described in this paper would provide a centralized system for access to non-public registration data. ICANN org would operate a central gateway to relay authorized third-party requests that meet policy requirements for access to the contracted parties. We believe that this model creates a secure, transparent, and predictable system for data subjects and parties requesting access to this data.
You may have heard this work described as the "Strawberry" project. I tasked an ICANN org team with developing the proposed UAM outlined in this paper. The purpose of this work is to seek clarity from the EDPB about whether such a model would be compliant with the framework of the European Union's General Data Protection Regulation (GDPR). Any guidance we obtain will be shared with the Expedited Policy Development Process team, to inform its ongoing work to develop a System for Standardized Access/Disclosure (SSAD). This paper also has been provided to Janis Karklins, the EPDP team chair.
I want to be abundantly clear that the UAM proposed in this paper is not intended to replace the ICANN community's existing policy development process. The goal is, as has been previously stated, to clarify whether such an access mechanism would be possible under the GDPR. This paper provides an important opportunity to solidify the legal foundation of a model, which will be factored into the work the community is conducting.
I want to thank the European Commission for its advice throughout the development of this paper. Their input has been invaluable. We look forward to hearing from the EDPB and sharing that feedback with the EPDP.
For more information, updates, and relevant documents, please visit our dedicated Data Protection/Privacy Issues page.