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The recommendations to be implemented by the Implementation Review Team ([[IRT]]) were shared with [[ICANN Organization]] to create an ICANN Consensus Policy that complies with the GDPR and other relevant privacy and data protection laws. In August 2022, a [[Public Comment]] proceeding was opened concerning the proposed Registration Data Consensus Policy for gTLDs. ICANN Org sought feedback on:<ref>[https://www.icann.org/en/public-comment/proceeding/registration-data-consensus-policy-for-gtlds-24-08-2022 Proposed Reg Data Consensus Policy, Public Comments, ICANN]</ref>
 
The recommendations to be implemented by the Implementation Review Team ([[IRT]]) were shared with [[ICANN Organization]] to create an ICANN Consensus Policy that complies with the GDPR and other relevant privacy and data protection laws. In August 2022, a [[Public Comment]] proceeding was opened concerning the proposed Registration Data Consensus Policy for gTLDs. ICANN Org sought feedback on:<ref>[https://www.icann.org/en/public-comment/proceeding/registration-data-consensus-policy-for-gtlds-24-08-2022 Proposed Reg Data Consensus Policy, Public Comments, ICANN]</ref>
 
# the collection, transfer, and publication of gTLD registration data, especially as it relates to
 
# the collection, transfer, and publication of gTLD registration data, especially as it relates to
#* the [[Thick WHOIS]] Transition Policy (Section 7)
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#* the [[WHOIS#Thick WHOIS|Thick Whois]] Transition Policy (Section 7)
 
#* the prohibition of personal data in the log file requirements relating to communications sent to RDDS/[[WHOIS]] Contacts (Section 11)
 
#* the prohibition of personal data in the log file requirements relating to communications sent to RDDS/[[WHOIS]] Contacts (Section 11)
 
#* Changes to processing requirements for administrative and technical contact data elements (Section 6)
 
#* Changes to processing requirements for administrative and technical contact data elements (Section 6)
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#* updates to existing policies and procedures that touch on Registration Data
 
#* updates to existing policies and procedures that touch on Registration Data
 
#* ICANN Org determined that 18 of 24 existing policies and procedures would be impacted by the Registration Data Consensus Policy, including outdated provision language, high-level issues, such as the relevance or inconsistency of an existing policy or procedure with the new Registration Data Consensus Policy, and implications for existing contractual provisions.
 
#* ICANN Org determined that 18 of 24 existing policies and procedures would be impacted by the Registration Data Consensus Policy, including outdated provision language, high-level issues, such as the relevance or inconsistency of an existing policy or procedure with the new Registration Data Consensus Policy, and implications for existing contractual provisions.
 
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===Public Comments Summary Report===
 
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On January 20, 2023, ICANN Org released its summary report on the 14 submissions it received. The summary identified several key themes, including:
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# the need for clarification in sections 2, 3, 5, 6, 7, 9, 10, 12, and addendums I and II.
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# areas in the drafted policy language did not accurately reflect the policy recommendations, such as "processing" in sections 1, the "scope" in section 2, the entirety of section 2.2, sections 3.8-3.10, and "consent" and "personal data" as they relate to the GDPR, the timeline in section 4, updates to section 5 to reflect events that have happened in the meanwhile, the use of "must" in sections 6, 7, 8, and 9, the use of "urgent," the proposed deadlines, and the lack of explanation for circumstances under which a request must be considered in section 10, issues with the specifics of logging in section 11, and the "minimum retention period" in section 12.
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# the need to correct some of the redlines in the Additional Whois information Policy, the [[ERRP]], the [[Protection of IGO and INGO Identifiers in All gTLDs Policy|Protection of IGO and INGO Identifiers]], the CL&D Policy, the Thick Whois Transition Policy, the Transfer [[FOA]] and initial authorization, the [[TDRP]], the [[Inter-Registrar Transfer Policy|Transfer Policy]], [[UDRP]]-related documents, the [[Whois Data Reminder Policy]] (WDRP) Rules, and [[RDAP]]-related documents.
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ICANN Org interpreted and summarized the public comments as outlining clarifications needed on requirements for the transfer of specific registration data from registrar to registry and the impact on the Thick WHOIS Transition Policy, changes needed to processing requirements for administrative and technical contact data elements and disclosure requirements, ensuring the Registration Data Policy is consistent with amended [[RA]] and [[RAA]], and updates to reflect the November 2022 adoption of The Network and Information Security ([[NIS2]]) Directive.<ref>[https://itp.cdn.icann.org/en/files/contracted-parties/public-comment-summary-report-registration-data-consensus-policy-gtlds-20-01-2023-en.pdf Public Comment Summary Report on Proposed Reg Data Consensus Policy, ICANN]</ref>
    
==References==
 
==References==
    
[[Category:EPDPs]]
 
[[Category:EPDPs]]
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