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The EPDP Initial Report on gTLD Registration Data is Published – Public Comment Period is Now Open

21 November 2018
By Rafik Dammak and Kurt Pritz

On behalf of the Expedited Policy Development Process (EPDP) Team considering the Temporary Specification for gTLD Registration Data, we are pleased to announce the publication of the team's Initial Report and opening of the Public Comment period.

As noted in previous ICANN blogs, the Temporary Specification approved by ICANN Board on 25 May 2018, expires one year from that date. The EPDP Team is working in a short period of time to provide a replacement policy for ICANN Board approval before the expiration date. The publication of this Initial Report maintains the feasibility of the plan for a timely replacement of the Temporary Specification.

The Initial Report responds to the call on the EPDP Team, mandated by the charter, to answer a set of questions and determine if the Temporary Specification for gTLD Registration Data should become a General Data Protection Regulation (GDPR)-compliant ICANN Consensus Policy as is, or one with modifications.

To develop a firm understanding of GDPR requirements and of the data processing that occurs in the Domain Name System's ecosystem, the EPDP Team documented each of the data processing steps, purpose, and lawful basis for each. This documentation was necessary for the EPDP Team to develop GDPR-compliant solutions that can be found in the Report's Appendix workbooks.

This work has been accompanied by several innovations: the creation of a parallel Adobe Connect meeting room for alternates and observers, the use of mediation techniques to build consensus, and the development of a new comment forum, described below.

This Initial Report provides preliminary recommendations and questions for the public to consider. The EPDP Team reached tentative agreement on many of these but there was no call for consensus. The EPDP Team members did not reach agreement on many other areas of discussion. The Initial Report describes areas of disagreement and provides specific questions on which the public may consider and provide comments with the purpose of guiding the EPDP Team's deliberations.

While it is customary for the chair of a policy working group to laud the team's hard work, this team of 31 members and 19 alternates held 29 fully-attended, multi-hour meetings in the 13 weeks available to it and also held 45+ hours of face-to-face meetings in Barcelona (at the ICANN meeting) and in Los Angeles. Small team meetings punctuated the brief intervals in between.

The Initial Report is now open for public comment until 21 December 2018. The EPDP Team will read and consider the comments submit while continuing its work.

A new format for collecting public comment was implemented for the purpose of this EPDP. This online, web-based format seeks to:

  • Link comments to specific sections of the Initial Report.
  • Encourage commenters to provide reasoning or rationale for their answers.
  • Enable the sorting of comments so that the EPDP Team can more easily read all the comments on any topic.

The online comment tool's functionality enables comments to be categorized to the specific sections of the Initial Report for which the EPDP Team is seeking community input. This will facilitate an efficient and in-depth review of the comments received – the thinking and rationale of the commenters, as opposed to whether they simply agree or disagree with a position. In addition to answering the specific questions noted in the Initial Report, participants will have the opportunity to provide comments on the general content of the Initial Report.

To preview all questions in this online form, you are welcome to download the Word version here. If you are unable to access the online form, you may submit your feedback directly using the Word form, only if you are unable to access the form online. However, use of the online form is strongly encouraged. It is important that you read the instructions on the first page and learn how to navigate through the form and save your progress.

For transparency purposes, all comments submitted to the Public Comment forum will be PUBLICLY displayed via an automatically-generated Google Spreadsheet. All comments, the name of the sender, and the organization listed will be displayed publicly. Email addresses will be redacted. If you wish to comment anonymously, type "anonymous" into the appropriate place on the form.

During the Public Comment period, the EPDP Team will seek advice on legal issues from the European Data Protection Board and others, as it deliberating on outstanding issues.

We look forward to hearing your feedback on the EPDP Initial Report. Thank you in advance for contributing to the public comment.


Kurt Pritz

Rafik Dammak