[Ncsg-discuss] our statement on DNS abuse associated domain check PDP

[farzaneh badii]

Hi NCSG

We have submitted this to the GNSO council based on our conversations and
deliberations with you.

This is an NCSG Statement. Bruna Dos Santos abstained on the DNS abuse
motion and we are submitting this to record NCSG's concerns and as an
explanation for Bruna’s abstention.

First, NCSG maintains its serious concerns regarding Associated Domain
Checks. We have consistently stated that ADC poses significant human rights
and profiling risks that must be addressed through robust safeguards.

Second, the Final Issue Report did not thoroughly address or adequately
respond to our public comments requesting transparency, due diligence
requirements, and remedy mechanisms for affected registrants. These
concerns were dismissed as not representing a "gap" due to "lack of data,"
rather than being incorporated as essential Charter requirements.

Third, we are concerned that the Issue Report relies heavily on external
reports that, while useful, are not holistic and do not consider or
interview all affected stakeholders—particularly domain name registrants
who may be harmed by these mitigation measures.

Going forward, NCSG calls for future DNS abuse policy work to be informed
by independent research designed in consultation with the ICANN community.
This will ensure studies consider all stakeholder perspectives and provide
a more holistic, balanced basis for policy development.

Going forward, we recommend that PDPs be informed by independent studies
commissioned by ICANN or the GNSO, with research design and methodology
developed in consultation with the community. While external reports have
merit and provide valuable data, policy development should not rely solely
on studies whose design and methodology did not consider the concerns and
perspectives of all affected stakeholder groups.

We will engage constructively in the Charter drafting process and expect
our substantive concerns to be adequately addressed in the Charter. Our
support for the final Charter will depend on whether it includes
appropriate safeguards for registrant rights.
Farzaneh
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