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ICANN org Seeks European Data Protection Board Input

Today, the ICANN org sent to the European Data Protection Board (EDPB) a paper, "Exploring a Unified Access Model for gTLD Registration Data," which outlines a proposed Unified Access Model (UAM) based on the Technical Study Group's technical model. The model described in this paper would provide a centralized system for access to non-public registration data. ICANN org would operate a central gateway to relay authorized third-party requests that meet policy requirements for access to the contracted parties. We believe that this model creates a secure, transparent, and predictable system for data subjects and parties requesting access to this data.

You may have heard this work described as the "Strawberry" project. I tasked an ICANN org team with developing the proposed UAM outlined in this paper. The purpose of this work is to seek clarity from the EDPB about whether such a model would be compliant with the framework of the European Union's General Data Protection Regulation (GDPR). Any guidance we obtain will be shared with the Expedited Policy Development Process team, to inform its ongoing work to develop a System for Standardized Access/Disclosure (SSAD). This paper also has been provided to Janis Karklins, the EPDP team chair.

I want to be abundantly clear that the UAM proposed in this paper is not intended to replace the ICANN community's existing policy development process. The goal is, as has been previously stated, to clarify whether such an access mechanism would be possible under the GDPR. This paper provides an important opportunity to solidify the legal foundation of a model, which will be factored into the work the community is conducting.

I want to thank the European Commission for its advice throughout the development of this paper. Their input has been invaluable. We look forward to hearing from the EDPB and sharing that feedback with the EPDP.

For more information, updates, and relevant documents, please visit our dedicated Data Protection/Privacy Issues page.

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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."