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Advice (sent to ICANN Board): GNSO Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data Policy Recommendations for ICANN Board Consideration
Summary TBDThe ALAC provided advice to the ICANN Board, noting significant concern related to three aspects of the EPDP Report. Specifically, the ALAC is concerned not only with the outcomes, but with the process that was followed to address the issues. All three impact the ability to access registration data and the completeness of that data, specifically: “to identify the appropriate balance for a path forward to ensure compliance with the GDPR while maintaining the existing WHOIS system to the greatest extent possible”. The ALAC advises the ICANN Board to:

• Request that the issue of Thick WHOIS be discussed during the EPDP Phase 2 in light of the new legal opinion;
• Request that the issue of geographic differentiation be re-opened during the EPDP Phase 2 in light of the new legal opinion and the lack of considering the competing needs of privacy vs the benefits of non-redaction on cyber-security activities and that the ensuing discussion factor in the needs of those using the data for cyber-security and other legitimate purposes;
• Request that the issue of legal/natural differentiation be discussed during the EPDP Phase 2 explicitly considering the competing needs of those using the data for cybersecurity and other legitimate purposes;
• Initiate independent studies related to the implementation of geographic and legal/natural differentiation as well as the impact of the Temporary Specification implementation on cyber-security, or request that the EPDP Phase 2 commission such studies. If the latter, the Board should ensure adequate funding for such work.

Comment (sent to ICANN Board): ICANN64 Joint GAC-ALAC Statement on EPDP
During ICANN64, the At-Large Advisory Committee (ALAC) and Governmental Advisory Committee (GAC) drafted and approved a Joint GAC-ALAC Statement on the EPDP. The GAC and ALAC are aligned overall with the EPDP Phase I Report, as it pertains to outstanding concerns as articulated in their respective statements to the report. The two advisory committees are in agreement on the need to distinguish between natural and legal persons. In addition, the GAC and ALAC highlighted the importance of data accuracy, the technical contact field, and protecting the public interest. The statement was drafted jointly with the GAC with input from the ALAC Liaison to the GAC, Yrjö Lansipuro, and GAC representative, Cathrin Bauer-Bulst, as well as the At-Large representatives to the EPDP, Hadia Elminiawi and Alan Greenberg.

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