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Make Your Voice Heard: Comment Now on the EPDP Phase 2 Initial Report

10 February 2020
By Janis Karklins


EPDP Team group photo taken in November 2019 during ICANN66 Montréal


On behalf of the Expedited Policy Development Process (EPDP) Team on the Temporary Specification for gTLD Registration Data, I am pleased to announce the publication of the Team's Phase 2 Initial Report and the opening of the Public Comment period.

The Initial Report sets out the EPDP Team's preliminary recommendations for a System for Standardized Access/Disclosure (SSAD) to Non-Public gTLD Registration Data. Please visit the Public Comment page for further information on how to submit your comment until 23 March 2020.

To facilitate your engagement in the Public Comment proceeding, the EPDP Team will host a 60-minute webinar on Thursday, 13 February starting at 14:00 UTC to provide details of our SSAD proposal and the related policy recommendations. All members of the ICANN community are welcome to participate and ask questions.

Initial Report Highlight

EPDP Phase 2 centers on the discussions around an SSAD. As described in a previous blog, the Team started our deliberations from the "hamburger model," consisting of a supply side and demand side of nonpublic registration data.

This model has now evolved into a detailed set of preliminary policy recommendations that form the proposed SSAD, including high-level principles, benefits for users, and an outline of the roles and responsibilities of the various parties involved in the operation and utilization of this system.

As you may recall, the SSAD is constructed using important building blocks that underpin its implementation. The building blocks address questions such as:

  • Who can request the nonpublic registration data?
  • What common elements must all requests contain?
  • What safeguards will be put into place to protect data subjects?
  • What actions do contracted parties (e.g., gTLD registries and ICANN-accredited registrars) need to take in response to an SSAD request?
  • Who is responsible for determining whether or not nonpublic data can be disclosed?

To understand the requirements of nonpublic registration data disclosure requests, the EPDP Team considered many questions, discussed a wide array of real-world use cases for users of the SSAD, and distilled the common themes that formed the building blocks.

These building blocks have evolved into 19 policy recommendations, which constitute the main body of our Initial Report. They cover various aspects including the accreditation of requestors, third party purposes and justifications, authorization, response requirements, variable SLAs, automation, and acceptable use policy.

It is important to note that all 19 of these policy recommendations are connected and should be considered holistically as the complete set provides the full details of the proposed SSAD.

The EPDP Team agreed to publish these preliminary recommendations for Public Comment, but no formal consensus call has taken place yet. The Initial Report also highlights areas where further input is requested and provides specific questions on which the public may provide comments to guide the EPDP Team's deliberations.


The publishing of the Phase 2 Initial Report is another great achievement for the EPDP Team. The Phase 2 Team of 31 members and 19 alternates held 42 fully-attended, multi-hour teleconferences in the past nine months. The Team also organized 100+ hours of intensive face-to-face meetings in Los Angeles, Marrakech, and Montréal. Small team meetings and mailing list discussions filled the brief intervals in between.

Everyone's dedication, willingness to compromise, and commitment to work through a multistakeholder process has pushed the EPDP one big step closer to our finish line.

We also appreciate the close engagement of the ICANN Board and ICANN organization (org), who provided us valuable input that informed our deliberations on the SSAD. If ICANN org receives further guidance from the European Data Protection Board, the EPDP Team will certainly consider this guidance as part of our deliberations towards our Final Report.

Last but not least, our thanks go to the EPDP Team's support staff, who worked tirelessly to advance our objectives every step along the way.

We look forward to hearing your feedback on the EPDP Phase 2 Initial Report. Thank you in advance for your contribution to the Public Comment.


Janis Karklins

EPDP Team Chair