ICANN- and Community-Proposed Compliance Models for Community Discussion

This page includes proposed models for compliance with the GDPR and ICANN contracts. These models were developed by both ICANN and community members.

The ICANN-proposed models represent input from across the ICANN community, data protection authorities, legal analyses, and the community-proposed models that had been received prior to publication of the ICANN models, and which are posted below.

The community-proposed models were submitted in response to the 2 November statement from Contractual Compliance. For more information about these proposed models, please visit the Guidelines for Proposed Models to Address the GDPR section of our Data Protection/Privacy Issues webpage.

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ICANN-Proposed Compliance Models

8 March 2018 – Interim Model for Compliance with ICANN Agreements and Policies in Relation to the European Union's General Data Protection Regulation – WORKING DRAFT FOR CONTINUED DISCUSSION [PDF, 923 KB]

This document presents a unified approach for how ICANN and the industry of more than 1,000 generic top-level domain (gTLD) registries and registrars could comply with existing contractual requirements and community developed policies concerning the processing of registration data, which includes personal data, in light of the GDPR. It represents an interim solution and does not replace the multistakeholder policy development and implementation activities that are underway. ICANN is publishing this working draft for community feedback as it works to finalize a model for adoption. Please send input to gdpr@icann.org.

28 February 2018 – Proposed Interim Model for GDPR Compliance -- Summary Description [PDF, 728 KB]

This document providing a high-level summary of the proposed final interim model, including a proposal for an accreditation program for continued access to full Thick WHOIS data for accredited users/entities. The legal justification for collection and use of the WHOIS data included in the interim model is not included in this summary document, but will be based on legitimate interests of the controller or third parties, and will be detailed in an analysis accompanying the Final Interim Compliance Model. See also below, the updated Working Draft Non-Paper [XLSX, 21 KB], which is chart comparing ICANN- and community-proposed models based on various elements of registration data against the proposed final interim model.

Please send your feedback to gdpr@icann.org, preferably prior to ICANN61, where we will continue this conversation on the direction we are taking toward interim compliance with the GDPR.

12 January 2018 – Proposed Interim Models for Compliance with ICANN Agreements and Policies in Relation to the European Union's General Data Protection Regulation [PDF, 624 KB]

These proposed models represent input from across the ICANN community, data protection authorities, legal analyses, and the proposed models we have received to date. This document represents a draft for community discussion and input. We are seeking your input on the proposals. From that input either variations or modifications to one of these models will be identified at the end of January for the path forward. To ensure we reach this goal, we need your feedback by 29 January 2018. Please send your feedback to gdpr@icann.org.

Community input, including proposed models for compliance, as well as the Hamilton firm's legal analyses, contributed to the development of these proposed models. Those documents are referenced below.

Community-Proposed Compliance Models

Model #	Date Submitted	Submitter	Submitter Organization	Documents
CM5	11 January 2018	Faisal Shah	Focus IP, Inc. dba Appdetex	Cover Page [PDF, 70 KB] Executive Summary [PDF, 70 KB] Details of Proposal [PDF, 70 KB] Template Questions [PDF, 70 KB]
CM4	11 January 2018	Frederick Felman	Personal Capacity	Cover Page [PDF, 70 KB] Executive Summary [PDF, 70 KB] Details of Proposal [PDF, 70 KB]
CM3	11 January 2018	Thomas Rickert	Eco Internet Industry Association	Cover Page [PDF, 70 KB] Companies / Groups Involved in the Development of the Proposal [PDF, 70 KB] Executive Summary and Proposal [PDF, 70 KB] Domain Industry Playbook [PDF, 70 KB]
CM2	21 December 2017	Dean Marks	Coalition for Online Accountability (COA)	Cover Page [PDF, 25 KB] Executive Summary [PDF, 26 KB] Details of Proposal [PDF, 102 KB] Working Draft GDPR Compliant WHOIS Model [PDF, 70 KB]
CM1	11 November 2017	Greg Aaron	iThreat Cyber Group	Strawman Proposal for WHOIS compliance with GDPR [PDF, 89 KB]