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ICANN org Responds to the European Data Protection Board’s Public Consultation on the Board’s Guidelines on the Concepts of Controller and Processor

BRUSSELS – 19 October 2020 – The Internet Corporation for Assigned Names and Numbers (ICANN) announced today that it has responded to the European Data Protection Board's (EDPB) public consultation on its Guidelines 07/2020 on the concepts of controller and processor in the GDPR. The EDPB is an independent European body whose purpose is to ensure consistent application of the General Data Protection Regulation (GDPR) and to promote cooperation among the European Union data protection authorities.

The issue of controllership has been critical throughout the work of the Expedited Policy Development Process on the Temporary Specification for gTLD Registration Data (EPDP) and remains important for the implementation of a System for Standardized Access/Disclosure as recommended by the EPDP Phase 2 Team.

In ICANN org's response to the public consultation, which closed today, it was noted that while the guidelines are a helpful step, ICANN org believes that further clarity would be beneficial in three areas:

  1. Precise attribution of "control" to particular stages in the processing under a micro-level analytic framework.

  2. When and how is "control" inferred from a contract, absent a party's actual involvement in processing contemplated under any such agreement.

  3. The newly introduced concept of "converging decisions."

The full response submitted by ICANN org is available here.

All contributions to the public comment will be available on the EDPB website.


ICANN's mission is to help ensure a stable, secure, and unified global Internet. To reach another person on the Internet, you need to type an address – a name or a number – into your computer or other device. That address must be unique so computers know where to find each other. ICANN helps coordinate and support these unique identifiers across the world. ICANN was formed in 1998 as a not-for-profit public benefit corporation with a community of participants from all over the world.

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Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."