Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
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Registration Data Consensus Policy for gTLDs
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INTA is pleased to provide our comments on 2 areas of the proposed recommendation. These are found in Sections 2 and 10 of the report. In Section 2, the recommendations do not accurately reflect the necessity and urgency of executing appropriate data protection agreements to cover the data collection, processing, publication, transfer and access activities contemplated by the EPDP Phase 1 Policy. In Section 10, the recommendations are inde...
The final NIS2 text was adopted by the European Parliament on 10-Nov-2022. The BC and other members of the EPDP frequently cited pending NIS2 regulation in our advice to create evolution mechanisms for registrant data policy. Unfortunately, the EPDP Working Group and GNSO Council did not follow that advice.
NIS2 now requires EU Member States to enact regulation that may render some EPDP policy recommendations in conflict with l...
The IPC appreciates the opportunity to comment on this draft policy, and we thank ICANN staff and the IPT for its herculean effort.
Among the concerns listed above, a primary concern for the IPC is that - as required by the EPDP policy recommendations - ICANN must enter into DPAs with Contracted Parties before it can implement this policy, not after.
ICANN must also ensure that this policy does not have the effect of overriding t...
In August 2022, ICANN published its Draft Registration Data Policy, requesting feedback from the community. We note that ICANN published the Draft Registration Data Policy as an outcome of the work of the Implementation Review Team (IRT) to develop an implementation plan in line with the Consensus Policy Implementation Framework (CPIF), which was previously developed by ICANN and adopted by the GNSO Council.
We welcome the work of ICANN ...
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The IRT to produce the proposed Registration Data Consensus Policy for gTLDs should be implement as soon as possible by the community.
The At-Large Advisory Committee (ALAC) has comments and concerns in regards to the following sections of this Public Comment proceeding:
(1) Section 4: Effective Date
(2) Section 10: Disclosure requests
(3) Background Section of the Registration Data Consensus Policy
(4) Thick Whois Transition Policy
Newfold Digital, Inc. thanks all current and past members of the IPT and IRT for their work. We believe the Registration Data Policy presented accurately reflects the recommendations but wish for the data processing agreements, recommended to be in place between ICANN and Contracted Parties per the EPDP Phase 1 Final Report, are completed at the earliest.
AFNIC appreciates the opportunity to provide comments and inputs on the Registration Data Consensus Policy for gTLDs. We also would like to convey our thanks to the working group, the community as well as the Implementation Review Team (IRT) and Implementation Project Team (IPT) for the work done one.
The draft Registration Data Policy mostly reflects the recommandations with regards to the collection, transfer, ...
The Registrar Stakeholder Group (RrSG) is pleased to comment on the Registration Data Consensus Policy for gTLDs and thanks the IRT team for their efforts. In general, it is the RrSG’s position that the policies accurately reflects the policy recommendations, with some suggested clarifications. The RrSG also notes that the questions in regards to transfers are under review by the PDP Transfer Policy Review PDP.
The Registries Stakeholder Group (RySG) appreciates the opportunity to comment on the Draft Registration Data Consensus Policy for gTLDs. The RySG has noted a few areas where we believe slight changes will provide beneficial clarity for those implementing the policy but overall, the RySG is supportive of the policy.
Further, the RySG did not specifically weigh in on each impacted policy in Part II of this comment as several a...
Regarding sections 6 and 7, there has been a lot of progress in governance and community institutions outside of ICANN multistakeholder process. These important achievements should not locked out of ICANN’s policies. Public identifiers are ways to improving the accountability of businesses while protecting the data of natural persons whose names should not be stored in corporate domain registration data. Even in the absence of a dedicated fiel...
The GAC welcomes the implementation of the EPDP Team Phase 1 final recommendations and appreciates the efforts of the team members. The GAC highlights several public policy concerns with the proposed implementation including issues related to: the definition and proposed timelines to respond to urgent requests; the collection and publication of reseller data; the collection/publication of registration information related to legal ent...
The i2Coalition would like to express support for the drafted Data Consensus Policy for gTLDs.
Tucows thanks the IPT and IRT for their many hours of work and diligent efforts in translating the Working Group Recommendations into Policy. The Registration Data Policy for the most part accurately reflects the Recommendations; Tucows has suggested modifications to Sections 5, and 10, Addendum I, and the Implementation Notes.