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In addition, the percentage of complaints received that lacked evidence of noncompliance or fell outside of ICANN org's contractual scope increased. For example, many complainants believe that the registration data is "missing" from the public Registration Data Directory Service (or WHOIS service), privacy or proxy service data are redactions, or all non-European data should be displayed. While Contractual Compliance efforts to educate complainants on contractual requirements increased, the number of actual investigations into registrars' compliance with registration data accuracy obligations decreased.<ref name="gdpr" /></blockquote>
In addition, the percentage of complaints received that lacked evidence of noncompliance or fell outside of ICANN org's contractual scope increased. For example, many complainants believe that the registration data is "missing" from the public Registration Data Directory Service (or WHOIS service), privacy or proxy service data are redactions, or all non-European data should be displayed. While Contractual Compliance efforts to educate complainants on contractual requirements increased, the number of actual investigations into registrars' compliance with registration data accuracy obligations decreased.<ref name="gdpr" /></blockquote>
===SSAD Design and Contractual Compliance===
At [[ICANN 72]], the [[SSAD]] [[Operational Design Phase]] team presented on the progress of the operational design phase for the System for Standardized Access/Disclosure.<ref name="ssadblog">[https://www.icann.org/en/blogs/details/ssad-odp-update-contractual-compliance-and-identity-verification-methodology-2-11-2021-en ICANN.org Blog - SSAD ODP Update: Contractual Compliance and Identity Verification Methodology], November 2, 2021</ref> The presentation included a description of the Contractual Compliance department's role in the new system. Noting that the "alert mechanism is not an appeal mechanism,"<ref name="ssadpreso">[https://www.icann.org/en/system/files/files/presentation-ssad-odp-project-update-community-discussion-28oct21-en.pdf ICANN 72 Archive - SSAD ODP Project Update Presentation Slides], October 28, 2021 (PDF)</ref>, the design team notes that compliance complaints could be filed within narrow procedural contraints in two categories:
* Procedural failures regarding alert mechanisms & complaints regarding contracted party behavior. For example, a contracted party fails to provide a sufficient rationale for a denial of an information request; or a contracted party dismisses a request without first seeking additional information from the requesting party; and
* Failure to respond to urgen requests within the timeframes listed in the contracted party's [[Service Level Agreement]].<ref name="ssadpreso" />
Although the design team anticipated that there may be changes in the scope and method of Contractual Compliance's complaint processes related to SSAD, the recommendations of the [[Expedited Policy Development Process on the Temporary Specification for gTLD Registration Data (EPDP)|EPDP on the Temporary Specification for gTLD Registration Data]] anticipate that the SSAD system will have its own processes, as well as avenues of legal recourse for people requesting registration data. As such, they presently anticipate that Contractual Compliance will have limited and specific involvement with the SSAD.<ref name="ssadpreso" />
==Monitoring==
==Monitoring==