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During development of the Temp Spec, contracted parties pointed out that this requirement would require development time to implement in their platforms.

15. Why city field is redacted in the Temporary Specification:

Regarding the EPDP Team’s question about why the City field is redacted in the Temp Spec, the Cookbook provides the following rationale: "The registrant’s state/province and country will be published, but the address fields that could be used to more specifically identify the registrant would not be included in the public WHOIS (e.g. street, city, postal code). This would enable non-accredited users to determine the registrant’s general location and likely jurisdiction but would generally not enable identification of the registrant”. The link to the Cookbook:https://www.icann.org/en/system/files/files/gdpr-compliance-interim-model-08mar18-en.pdf. The above quote is on page 26.


EPDB Advice

  1. Can ICANN summarize in some searchable form the contacts and engagements with the EDPB and/or other DPAs in relation to the Temporary Specification for gTLD Registration Data?

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Input from ICANN Compliance

Contractual Compliance responses to EPDP_25jan19.pdf

Summary-Contractual-Compliance-Data-Processing-Activities5oct18.pdf


OUTSTANDING QUESTIONS

  1. Is indemnification provided by ICANN through a joint controller agreement an option? If EPDP agrees on policy that requires ICANN to indemnify, would the ICANN legal team and Board oppose it?

  2. When will the ICANN be released memorandum concerning the roles and responsibilities in processing data. The EPDP team encourages ICANN to issue the memo within 48 hours so its position can be referenced in the Initial Report.