At-Large Workspace: ALAC Feedback on EPDP Phase II

Public Comment Close	Statement Name	Status	Assignee(s)	Call for Comments Open	Call for Comments Close	Vote Open	Vote Close	Date of Submission	Staff Contact and Email	Statement Number
21 June 2019	ALAC Feedback on EPDP Phase II	DRAFTING	Alan Greenberg Hadia Elminiawi

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EPDP Phase II

Reference: "Expedited Policy Development Process (EPDP) on the Temporary Specification for gTLD Registration Data – Phase 2 Input Template, 30 May 2019":

CPWG presentation:

Reference: 9 June email from EPDP II Chair Janis Karklins with "EPDP Team input in response to GNSO Council's request":

EPDP Input -

Email message -

Dear Keith,

Following the request of the GNSO Council for the EPDP Team to identify any questions, comments or concerns to be shared with the ICANN Board in relation to their action on the EPDP Phase 1 Recommendations, 3 groups provided their feedback (see Annex A) which the EPDP Team discussed during its meeting on 6 June 2019. Although there was not sufficient time to formalize and agree on an EPDP Team response, the team felt it important to share the different perspectives with you to help inform the Council’s preparation for the consultation process with the ICANN Board. My take-away from the discussion was that:

In relation to purpose 2, there is general understanding for why the Board decided to not adopt this purpose and the EPDP Team confirms that it considers it firmly within its scope for phase 2 to further review this purpose in the context of the System for Standardized Access / Disclosure (SSAD);
For recommendation #12, some additional context has been provided that may help explain the thinking behind the EPDP Team’s original recommendation. However, there is no agreement at this stage on whether or not the Board’s non-adoption should be supported.

The EPDP Team understands that following the GNSO Council’s consultation with the ICANN Board you will follow up with us to provide an update on dialogue with ICANN Board and request further input on the possible next steps for GNSO Council. The EPDP Team stands ready to assist as needed.

Best regards,

Janis Karklins

Reference: AIs from 22 May CPWG call

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FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

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DRAFT SUBMITTED FOR DISCUSSION

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Hadia El Miniawi

June 12, 2019 at 1:08

With regard to recommendation #1 purpose 2, which the board did not adopt and as this purpose was initially a place holder for further review in phase 2. The ALAC would like to make a proposal in relation to the purpose, taking into consideration the board's rational for not adopting it, the European Council (EC) comments on the team's final report and the previously provided guidance by the European Data Protection Board (EDPB). We suggest replacing purpose two of recommendation one by " Serving the public interest by maintaining the security, stability and resiliency of the DNS in accordance to ICANN's mission and bylaws".

The rationale behind our proposal is that all purposes should strictly be ICANN purposes, moreover "enabling responses to lawful data disclosure requests" is not a purpose but rather a processing activity.

The aforementioned purpose will need to be analyzed just as we did with all the other purposes in order to determine the processing activities associated with it. The lawful disclosure to relevant third parties as well as to ICANN if requird would result as a processing activity required to satisfy the purpose.

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