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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The NCSG supports the continued operation of the RDRS beyond the pilot phase, but this extension must be conditioned on meaningful improvements to transparency and accountability. The process for authenticating law enforcement and other requestors must also be clearly documented, publicly accessible, and subject to independent oversight.
Additionally, and to reiterate prior NCSG comments, registrars must not simply passively render requests, but rather actively conduct documented evaluations of the fundamental rights at stake, such as by conducting a community impact assessment. Privacy, freedom of expression and process are integral to ensuring the safety and security of end-users and the stability of the DNS
Finally, RDRDS should not be made mandatory for registrars.