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Data Protection/Privacy Issues Update: Discussion with Article 29

Gdpr data protection privacy article29 750x433 07mar18 en

As we prepare to depart to San Juan for the ICANN61 meeting, I wanted to provide you with the latest update on our efforts related to compliance with the European Union's General Data Protection Regulation (GDPR). There have been a number of webinars and calls organized by various constituencies in the last few days, in which ICANN org colleagues and I have participated, giving us a chance to further exchange views as we refine the proposed model.

On 2 March, we had a useful discussion with the Article 29 Working Party regarding our recent publication of a Proposed Interim Model for GDPR Compliance. During that conversation, we summarized the elements of our Proposed Interim Model and shared the valuable feedback we have received from community members, including where viewpoints on the proposed interim models have diverged. In addition, we emphasized the importance of a common approach for the organization together with the registries and registrars. The Article 29 representatives noted the progress we have made in developing a plan of action to comply with the regulation, and expressed their willingness to review the Proposed Interim Model in more detail, particularly regarding the purposes for the collection and publication of data, the data retention period, data processing agreements, and the justifications surrounding access to full registration data for accredited users. We are also looking forward to a deeper exchange with the Article 29 Working Party later in March on the rationale for the interim model. The data protection authorities will continue their internal coordination through March, taking into account further details coming from ICANN on the final model, and we plan to touch base with them then, and into April when the Art 29 WP holds its next plenary meeting. We hope that they will be able to publish feedback.

In the meantime, I am looking forward to continuing this discussion with you at the San Juan meeting, either in person or via remote participation.

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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""icann.org"" is not an IDN."