closed Registration Data Request Service (RDRS) Policy Alignment Analysis

Outcome

The ICANN organization appreciates the comments submitted by the community on the RDRS Policy Alignment Analysis. ICANN org received 13 submissions which generally support the goals and direction of the RDRS Policy Alignment Analysis, particularly the intent to improve consistency, predictability, and transparency in registration data disclosure processes. However, support was frequently paired with requests for clarification, limitation, or future policy work before broader adoption or expansion.

The common themes of overall feedback include:

• Governance and policy alignment clarity
• Voluntary vs. mandatory registrar participation
• Law enforcement or government access
• Liability and legal risk
• Cost, resourcing, and operational burden
• Scope limitations and future expansion concerns.

Privacy compliance, law-enforcement access, and request response timing concerns, including urgent requests were the most prevalent themes.

What We Received Input On

The purpose of this open proceeding is to collect community input and generate community discussion on the proposed roadmap for aligning the RDRS-related policy gaps identified in the paper and to help inform discussions between the ICANN Board and the Generic Names Supporting Organization (GNSO as they assess the work of the Privacy and Proxy Services Accreditation Issues (PPSAI) IRT and Registration Data Policy IRT and begin to discuss the consensus policy recommendations for an System for Standardized Access/Disclosure.

Background

ICANN org launched RDRS on 28 November 2023 with the intention of operating the service for up to two years. This was a result of the ICANN Board’s direction to ICANN to analyze usage of and demand for a system that handles requests for gTLD nonpublic registration data. The purpose of the RDRS is 1) to collect system usage data to inform the future discussion between the GNSO Council and the ICANN Board on the policy recommendations outlined in the EPDP Phase 2 Final Report , and 2) to provide a cost-effective system that will simplify the process for submitting and receiving requests for gTLD nonpublic registration data for both the requestors and registrars.

The ICANN Board and community began to discuss next steps regarding the future of the RDRS during ICANN81, including the future of the GNSO consensus policy recommendations concerning an SSAD, the impact of the PPSAI IRT policy work on disclosure of underlying privacy/proxy registration data, and the two tracks of work of the Registration Data Policy IRT on a response time for urgent requests and law enforcement authentication. The GNSO Council during its meeting on 13 November 2024 also discussed whether it would be appropriate for the Council, following receipt of the GNSO Standing Committee’s findings and recommendations, to reconsider the approved 18 policy recommendations from the EPDP Phase 2 Final Report, which recommended the development and implementation of an SSAD. The Council concluded that either revising or otherwise revisiting the approved SSAD recommendations would be the best next step.

Supporting Information