[NCSG-PC] IDNs EPDP: Review of proposed language changes for Recommendations 14 and 15 – Alignment with NCSG's public comment

[Emmanuel Vitus]

Dear NCSG Members,

I hope this message finds you well. As your representatives in the IDN
EPDP, Peter and I would like to inform you about some recent developments
concerning the proposed changes to Recommendation 14 and Recommendation 15,
shared by the Chair of the IDN EPDP working group. These changes were
presented as we continued to revise the public comment on the EPDP draft
recommendations. Leadership has requested that we review these proposals
and provide feedback.

*Recommendation 14:*

The revised language separates two key concepts:
- Ensuring communication between registries and registrars to enforce the
'same entity' principle regarding variant domain names.
- Providing a mechanism for end users to discover the allocated variant
domain names for purposes like registering a domain or filing a complaint.

Under the new language, responsibility is given to gTLD registry operators,
who will work with ICANN-accredited registrars to provide necessary
information about the allocated variant domain names, including the source
and initial source domain names.

*Recommendation 15:*
The changes to Recommendation 15 address privacy concerns raised by ICANN
Legal, indicating that disclosing allocated variant domain names could
reveal details about the registrant that may unintentionally compromise
privacy. Registrars are now expected to evaluate whether to disclose this
information based on balancing the interests of the requestor and the data
subject, in line with applicable privacy laws.

*NCSG’s Position:*
* These changes align well with the comments we raised in our public
submission during the review process, particularly regarding the protection
of personal data and ensuring that any handling of variant domain names
respects applicable privacy laws. The revisions strike a careful balance
between transparency and privacy, which is in line with the principles that
NCSG has always advocated for.*

*Recommendation:*
Since these proposed changes reflect our earlier feedback and address
concerns outlined in our public comment, Peter and I recommend that we
accept the updated language for Recommendations 14 and 15.

Please feel free to provide your thoughts or questions.

Best regards,

Emmanuel & Peter
NCSG Representatives, IDN EPDP
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