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Public Comment

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.

Name: Lucien Castex
Date: 21 Nov 2022
Affiliation: AFNIC
Please provide your feedback:
Section 1 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 2 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

The expression “other purposes” should be further clarified to identify what purposes would be covered under section 2.2.

Please provide your feedback:
Section 4 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 5 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

The section should be clarified in particular with regard to the obligation for the parties to "enter into required data protection agreements", either under applicable law or the aforementioned policy recommandations.

Please provide your feedback:
Section 7 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

Further clarification is needed regarding the obligation to have a Data Processing Agreement.

Please provide your feedback:
Section 11 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 12 does not accurately reflect the intent of the Registration Data Consensus Policy. (Please provide an explanation including Recommendations from the EPDP-TempSpec Phase 1 or Phase 2 Final Report where there are inconsistencies and the suggested change to make this section consistent.)

If B, C, or D, please elaborate.

Section 12 only sets sets a minimum retention period of no less than fifteen (15) months. The Provision should be further reviewed considering article 5 of the GPDR and data minimisation principles.

Please provide your feedback:
Addendum I accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Addendum II accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Implementation Notes accurately reflect the policy recommendations with no issues.
Please provide your feedback:
Background Section accurately reflects the policy recommendations with no issues.
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the AWIP correct?
Yes
Summary of Submission

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, and publication of gTLD registration data but further clarification and slight modifications are needed to allow for a clear and consistent implementation of the policy.