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ICANN Org Comments on European Data Protection Board (EDPB) Recommendations 01/2020 on Measures That Supplement Transfer Tools to Ensure Compliance with the EU Level of Protection of Personal Data

BRUSSELS – 21 December 2020 – Today, the Internet Corporation for Assigned Names and Numbers organization (ICANN org) submitted a comment to the European Data Protection Board, concerning its recommendations 01/2020 on measures that supplement transfer tools to ensure compliance with the European Union (EU) level of protection of personal data. This comment follows ICANN org's comment submitted to the European Commission (EC) on 10 December 2020 concerning the EC's updated standard contractual clauses for transferring personal data to non-EU countries.

ICANN org's comment raises concerns related to the potential impact of the recommendations, particularly related to transfers of personal data from the European Union to the United States. This comment encourages the European Data Protection Board to adopt a risk-based approach to determining the safeguards that must be applied to make the transfer of data GDPR-compliant.

The full comment submitted by ICANN org is available here.

All contributions to 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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Domain Name System
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."