[lac-discuss-en] RV: ICANN News Alert - ICANN Seeks Public Comment on 2013 RAA Data Retention Specification Data Elements and Legitimate Purposes for Collection and Retention

asoto at ibero-americano.org asoto at ibero-americano.org
Thu Apr 3 23:57:06 UTC 2014


[[--Translated text (es -> en)--]]

 Subject: Re: RV: ICANN News Alert - ICANN Seeks Public Comment on 2013 RAA Data Retention Specification Data Elements and Legitimate Purposes for Collection and Retention 
 From: asoto at ibero-americano.org

 Impeccable Ada. The period I had said was to discuss the 
 list, but until now there were only three comments. The term 
 pblicos comments estarabierto to 23:59 UTC on April 21. 


 Thank you and congratulations on your dedication! 






 Alberto Soto 






 From: Aida Noblia [mailto: aidanoblia at gmail.com] 
 Posted on: Thursday, April 3, 2014 08:36 pm 
 To: Alberto Soto 
 CC: Fatima Cambronero; LACRALO Espaol 
 Subject: Re: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN 
 Seeks Public Comment on 2013 RAA Data Retention Data Elements Specification 
 and Legitimate Purposes for Collection and Retention 






 Hello everyone: 






 Thanks Alberto for comprehensive information. Also not to bore and 
 I have direct information, leave the link to the government site where 
 legislacin are national and some of the Latin American and 
 national jurisprudence <http://www.datospersonales.gub.uy/>
 www.datospersonales.gub.uy. 


 Although the term is not estvencido you posted if the comment period 
 or at least as Decas understand that the issue is very important. 


 That and because I can not send this wiki because I can not enter because 
 There were problems with the wiki, mailing them this vein that drafted 


 A couple of comments, which are requested prior to focus specifically on 
 the declaration: 


 On the one hand these new rights to access personal data and information, 
 ESTN will still not incorporated in the paradigms of the people, it is very 
 asymmetrical process, many do not know it, human rights are new 
 generation of the Digital Age, will inserting into the consciousness of the 
 people.


 In different countries the real gap is so great that many people do not 
 understand that these are your rights, claiming that ESTN other 
 emergency department: safe streets, stop violence, hunger, right 
 health, etc.. 


 I understand that from the point of view of ICANN's good to know these 
 provisions topic has already been studied for the last time in the EWG 
 According mencionCarlton in B. Aires last year. 


 On the other hand: the same laws have exceptions, pretty 
 strict and limited, even in respect of periods of comunicacino 
 preservation of data, there are other community interests 
 priority, eg set them in the bublic data sources or lists, 
 Database or the Central Bank on credit data, or the 
 characteristics determined by law. What are the exception pblicos 
 the data of your credit responsibility of persons (defaults, 
 etc.) for a specified period, for protection of stability 
 financial market.There are also other for certain FIELDS, but 
 to omit the subject to focus on, we ESTN in laws. 


 In the specific case raised from the declaration, the exencin occurs for 
 protect interests of records, given their difficulties in 
 meeting legal standards, according to the statement made by the interested parties. 


 I think from the point of view of ICANN's good to know the 
 laws, an issue that has already been studied in the EWG According mencionCarlton 
 B. Aires last year. 


 But it is also necessary to consider the specific reason and 
 proposed target is a particular problem, referred to the 
 Declaration dealing with the issue of establishing an appropriate policy of ICANN 
 globally, that can address the needs of the services 
 provides, without prejudice to laws, but assume no responsibility for 
 issues that do not belong legally and without exemptions, the 
 case, impair the reliability, stability and safety 
 ICANN provides service to the community.Establishing the new AAR 
 applicant's responsibilities and recorder, which, by 
 exencin procedure referring to the Declaration under study, 
 Free registration to release the preservation of data. 


 Aquhay solve a particular problem is not only in this 
 Declaration on the matter on which they are made these comments. ICANN not 
 you can free the parties to a legal obligation because it has 
 powers for that. Try to solve the problem for hold serve 
 reliably and safely, mxime with the new risks posed by 
 new gTLDs. But it is not and never was the owner of the database or which 
 receive and control data or maintained. 






 That was an obligation to the applicant, who will pay for 
 manage the domain and is entitled to claim that you pay as 
 legal. Also the applicant has in turn obligation to provide 
 and update data.That &quot;bottom-up&quot; system applies regarding the 
 as cooperation and responsibility for system operation 
 global, because who is the owner of the data is that estprotegido by 
 the system, usually the more interested in protecting their data, and that 
 ms can contribute them directly in the minimum time. 






 On the issue of liability, which is the game who are in the 
 Records if you're seeing, it is very clear who they are the 
 responsible and qu. Whether the new RAA (Registracin Agreements) 






 In other cases even legal exemptions to the preservation of data 
 personal, for example in Uruguay, with regard to the credit bureau 
 credit that mencionantes, expressly provides that persons 
 physically challenged and legal bodies of the system of financial intermediation that provide 
 the information contained in the Central Credit Risk by the 
 Central Bank of Uruguay Sern the Nicaraguan responsible for the accuracy and 
 Upgrading of the same. 






 The database takes the Central Bank, which is a third, but remains 
 clearly not responsible for the content of the database because only maintains 
 one computer system based on data that are provided. It is this 
 responsibility who are game, which is governed by the logic of justice 
 responding by themselves or dependent events. The Bank responds 
 the proper functioning of the computer system holding base 
 data online. 






 I understand that in the case of ICANN, any exencin be made, it should be 
 expressly stated that ICANN does not assume responsibility for any 
 reglamacin that might arise in this regard. This I can not overemphasize 
 importance to ICANN interspblico defense and compliance 
 their own purposes. 






 The problem arises reason of the complexity added by the incorporation of 
 new gTLDs, which increases exponentially the Administration and 
 handling a much larger amount of data, which means reception, 
 control data quality, conservation, modification processes 
 where appropriate, or if cancelacin. The way in which regulates 
 Now mejorarindidablemente the quality of data and service 
 general. 






 The position of the records before this is trying to break free from the 
 complexity and in the case of the obligation of preservation of data Ass 
 have these problems and these responsibilities, but ms delegacin 
 there, ICANN is not and never was the owner of the database are as 
 earlier records responsible recoleccin as both the 
 conservation. 






 The interest of ICANN, is not the same as the registers, it is more 
 Overall, properly manage and secure and reliable Internet 
 and all domains.Must be address the interests and needs of 
 PARTS AND all involved, that's what your own funciny 
 purpose. In this case, ICANN requires desempear well the function that has 
 good of the Internet community, not in their benefit, working 
 for the same security network and generated the least amount possible 
 Conflict: accurate, relevant, not excessive, and timely data ... 
 quality and quantity of data, delete Erroneous, extemporneos data 
 store the necessary for the time necessary to better meet your 
 function. 






 The records remain responsible base as always, what 
 they can handle in maintaining recolecciny data, but with 
 a specialized service that supports them so that they can better fulfill their 
 function in the new era and these new domains. What is outsourced 
 to improve is a part of their work, which is part of your business. This 
 is not a criticism, but simply the situation is in fact what we are 
 expressing. 






 I understand why estbien the Declaration, agree with it and 
 with trying those who are responsible and have its economic advantage in 
 activity they provide, also comply with the rules properly, and 
 that if ICANN internally exonerate the relationship, arise 
 sb injury is not ICANN OF ANY way responsible for it, 
 subsisting liability on those who have legally. although they 
 but involves higher costs. I understand this must be expressly 
 drawn up and signed by both parties. 






 Otherwise injured party will be able to understand that ICANN exempt 
 registrars of the responsibility is on the keychain subrogating 
 consequences that may prepare legal bodies for the fact registrars 
 not comply with the conservation of the data. 


 Greetings to all 






 The March 27, 2014, 0:58, Alberto Soto <asoto at ibero-americano.org 
<mailto:asoto at ibero-americano.org> &gt; Wrote: 


 Ada and all.Our laws (Uruguay and Argentina), inspired ESTN 
 LSI espaola, asque may differ somewhat in form but not in substance. 
 Argentina's Law of Personal Data Protection does not speak of retention of 
 data communications. S, there was a law on this last topic, but was 
 left in suspension by the numerous criticisms received. 


 The Act Argentina is the No. 25326, which also defines personal data 
 (Information of any kind referred to physical persons or existence 
 ideally determined or determinable; and sensitive data (personal data 
 revealing racial and ethnic background, policies opinions, convictions 
 religious, Philosophical or moral, union affiliation and information 
 concerning health or sex life).


 Also defines Data processing: Operations and procedures 
 sistemticos, electrnicos or not, enabling the recoleccin, conservation, 
 ordenacin, storage, modification, relationship, evaluation, 
 blockade, destruction, and general processing of personal data, as 
 as also his third cesina to Travs communications, consultations, 
 interconnections or transfers. 


 With regard to information security, our law says: 1. The 
 responsible or user data file must adopt measures techniques 
 and organizational measures necessary to ensure the safety and 
 confidentiality of personal data, in order to avoid adulteracin, 
 loss, or unauthorized consultation, and to detect 
 deviations, intentional or otherwise, of information, whether the risks 
 from human action or technician medium used. 


 Two. It is prohibited to record personal data in files, records or 
 banks not renan techniques Payment integrity and security. 


 Regarding confidentiality: 1.And responsible persons 
 involved at any stage of the processing of personal data ESTN 
 bound to secrecy regarding the same. Such obligation 
 subsistiraun completed after his relationship with the owner of the file 
 data. 


 Two. The forced podrser relieved of secrecy by resolution 
 court and for compelling grounds relating to public safety, 
 national defense or public health. 


 Regarding the Cesin Data: 1. Personal data object 
 treatment can only be assigned to fulfill the purposes 
 directly related to the legitimate interest of the transferor and 
 assignee and with the consent of the owner of the data, which 
 must be informed about the purpose of identifying the CESINE 
 transferee or the elements to do so. 


 After this long introduction, I must agree with you on virtually 
 everything. 


 I understand that both a Registrar as a Registrant, have (or MUST 
 have!) an appropriate technology infrastructure needs.This is 
 say that they have an adequate system of information security, with 
 separations between their servers and production management areas, 
 including systems development if they have this area. In addition to 
 its internal communications network, separated and denied access 
 between different areas, elemental a service provider 
 internet. This, in addition to comply with the local laws of protection of 
 personal data. 


 This would involve, for example, that the data elements described in the 
 points 1.1.8 (Processing recurring payments); and 1.2.1. (Information 
 on concurrent payments) ESTN sheltered in a different place 
 elements Whois data, which access to them is 
 only possible for this last free, and internal staff 
 registrar or registrant to information of the aforementioned tems, which 
 contain associated names, credit cards, addresses, etc.. It 
 states that if the source of payment information is deleted, not a registrant 
 tendrmanera evaluate claims dispute facturacino 
 Returns the position of the process.In many cases in dispute with 
 credit cards or bank charges. 


 The legislation this estrelacionado with each country. In Argentina, the 
 credit cards and banks have the obligation to keep such 
 of information for many years; at this time I do not remember if there are seven 
 or ten years. If as there are at least two places with information 
 necessary. 






 With regard to the issues of hacking, irregular domain sale by deception 
 Buyer, etc.., speaks of a aooms of data retention. This 
 term must have prescripcin relationship with the crime, 
 because if barred two years, I should not keep them for three years. 


 I understand that retention periods are set, because this issue has been and 
 remains very controversial because it requires storage measures 
 additional security, etc.. And msan being traffic data. 






 I hope I have not bored 


 Best Regards 






 Alberto Soto 






 From: Aida Noblia [mailto: aidanoblia at gmail.com <mailto:aidanoblia at gmail.com> ] 


 Posted on: Wednesdays, March 26, 2014 4:55 pm 
 To: Alberto Soto 
 CC: Fatima Cambronero; LACRALO Espaol 




 Subject: Re: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN 
 Seeks Public Comment on 2013 RAA Data Retention Data Elements Specification 
 and Legitimate Purposes for Collection and Retention 






 Fatima, Alberto, Alejandro and all 






 Ses understand that a very important issue, and also in the complex 
 laws, I could not attend the roundtable mencionFtima is 
 You can listen any recording? is still some time for 
 comments? I am not clear what is the closing date for comments. 






 National legislation on protection of personal data are 
 rather strict, and also the right of access to information 
 pblica because ahestara the limit necessary to know what can and 
 must publish and what not, with quextensin, for how long, quines 
 they can do it, you can publish lbremente qudatos cules and require 
 free, express, written consent of the owner ... 






 In Uruguay the Law 18331 and its implementing regulations refer to the 
 protection of personal data (qualified in two types (sensitive or not) 
 As a human right protected by the constitution of the Republic. It 
 provides the owner of the personal data ARCO rights acronym that 
 level legislation includes right to access the database, 
 Corrigendum of Erroneous or modified in reality data correction 
 of Erroneous or inaccurate data and Oposicina done what the law calls 
 &quot;Treatment&quot; of the data that is generally any use of such data 
 personal, without the express written consent of its owner.






 There is a Regulatory Unit Registration and Control of such data by the 
 Agency electronic government, in the Register of the Specifications 
 contain mandatory for all personal data that has a base, and 
 is of public or private persons, controls, and procedures performed 
 auditing and punishing violators with fines and even closure of the 
 database. 






 There is a base charge and take charge of the practice by 
 account of others or their own. The law regulates their responsibilities. The 
 Database Owner, or physical person jurdica is responding by 
 use or processing of personal data to the owner of that data. 






 An when they can use or deal in certain circumstances, 
 consent of the owner or in cases of data that supports your 
 treatment without l, personal data can not be used for other 
 purposes for which the owner permitted use. 






 The base is responsible for its own use or who decides: The data 
 personal is collected for a purpose and should be eliminated one 
 Once cumplila purpose for which it was collected, can be 
 transmit only in certain conditions .. etc.. It is the responsibility of the 
 base, which can be physical or legal person to whom the owner of the 
 Data may be enforced or penalties that may apply. 






 With variations, this is repeated in the legislation. In case of transfer 
 international data international law applies, and therefore there will 
 to analyze what is the applicable law and jurisdiction competition. 










 In the case of ICANN, the owner of the database is not ICANN, for 
 therefore is not legally responsible for processing that may occur to the 
 personal data. 






 According saw, in the system of the new agreement, the service is outsourced, 
 To improve it in terms of the quality of the data and also about its 
 treatment, but that does not mean the change of ownership. 






 So ICANN agrees the &quot;excencin&quot; of data retention in some 
 analyzing specific cases and by a special procedure, but 
 harming the intended service users improve this 
 new medium. 






 This is done at the request of the records to be released from their 
 liability because by not having to keep the data in accordance with 
 According to ICANN no longer have to answer to the law for their 
 conservation, damage, misuse, etc.. It emphasizes the need for the 
 good faith by the owner or holder of the database (check in) 
 which contains the data, though this good faith is a matter of difficult 
 certain proof. 






 Also, to not keep such data prevents any possibility 
 fulfill the functions of ICANN in such cases, with respect to the prevention of 
 damages that may result from misuse of domain names and 
 similar. 










 The issue in each case is to analyze these requests, if you really 
 retention of such data is necessary for the service prestacin 
 to Travs registry is provided or if it constitutes a violation of the 
 law. The blog that cases can be referred to and do not appear 
 so rare. And the position of registrars is clearly find that 
 facilitate their task. but in this case may be against the effectiveness and 
 completeness of the service provided by ICANN. From what has already been given and can 
 see on the web, it seems that security prevails. But the ms allde 
 presentation requirements of having the case (with reports of attorney, etc. 
 ) Should be studied very well in that case is given rather than presumed 
 good faith as a way to resolve these cases. 






 Otherwise give an endorsement by the owners of the Records 
 released from liability, affect the risk of compliance 
 other obligations, affect all other obligations of the 
 Register and its owner as dueoo who treats data. 






 As decan seems a matter of interest. 










 Regards 






























































 3/22/2014 20:59 GMT-03: 00 Alberto Soto <asoto at ibero-americano.org 
<mailto:asoto at ibero-americano.org> &gt;: 






 Fatima, only Sern 04:00 am in Buenos Aires but I promise participate. 


 Thank you! 






 Alberto Soto 






 From: Fatima Cambronero [mailto: fatimacambronero at gmail.com 
<mailto:fatimacambronero at gmail.com> ] 
 Posted on: by saturday, March 22, 2014 8:54 pm 
 To: Alberto Soto 
 CC: Dr. Alejandro Pisanty Baruch; LACRALO Espaol 
 Subject: Re: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN 


 Seeks Public Comment on 2013 RAA Data Retention Data Elements Specification 
 and Legitimate Purposes for Collection and Retention 






 Alejandro, Alberto, 






 I share the view of that we are facing an interesting topic 
 deberamos to analyze and speak out from our region. 






 The da Monday 24 at 15 pm. Local Singapore estprevista a Table 
 Round about Directory Services Registration: present and future. If 
 While this issue is not specifically on the agenda estincluido of the meeting is 
 closely related perhaps a topic that appears in the discussions. 






 It will be good to participate in this Roundtable to hear and discuss the 
 comments you may have about it. I understand that the hours of 
 our countries is in a strip a little complicated. I'll be 
 attending this meeting. If there sb who want to comment or view 
 to get, I offer to transmit. 






 This is the link to the agenda of the Roundtable: 
 https://community.icann.org/display/atlarge/At-Large+Roundtable+on+Registrat 
 &lt;  https://community.icann.org/display/atlarge/At-Large+Roundtable+on+Registra 
 tion + Directory + Services% 3A + Now + and + the + Future + - +2014.03.24 + - + Singapore&gt; 
 ion + Directory + Services% 3A + Now + and + the + Future + - +2014.03.24 + - + Singapore 






 That link to the Adobe Connect:  https://icann.adobeconnect.com/sin49-vip/ 
 (This is the same for all meetings of At-Large of the week). 






 Best Regards, 


 Fatima Cambronero 






 3/21/2014 23:40 GMT-03: 00 Alberto Soto <asoto at ibero-americano.org 
<mailto:asoto at ibero-americano.org>


<mailto:asoto at ibero-americano.org <mailto:asoto at ibero-americano.org> &gt;&gt;: 




 I think the interest should be sufficient. It is just one of the topics 
 make the existence of end-user oriented entities Internet 
 ie U.S.. 
 Surely there are different laws for each country, at least in 
 some substantial tems. Although there are countries that do not have an legislation. 
 There are 30 days for comments, there is little time for the importance of the subject. 
 Suggest that very quickly the respective ALS each country of our 
 Regin, read the history of this item, then inform the 
 legislacin force in their respective country, with reviews.Also I suggest 
 that for this first phase, the closing date is the Friday Prximo 
 28/03/2014. 
 Also suggest that those who are participating in Singapore, are exempt from 
 participate, have very important things to do for us. 


 Best Regards 


 Alberto Soto 


 ----- Original Message ----- 
 From: lac-discuss-es-bounces at atlarge-lists.icann.org 
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org>
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org 
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org> &gt; 


 [Mailto: lac-discuss-es-bounces at atlarge-lists.icann.org 
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org>


<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org 
<mailto:lac-discuss-es-bounces at atlarge-lists.icann.org> &gt;] On behalf of Dr. 
 Alejandro Pisanty Baruch 
 Posted on: Friday, March 21, 2014 11:25 pm 
 To: lac-discuss-es at atlarge-lists.icann.org 
<mailto:lac-discuss-es at atlarge-lists.icann.org>


<mailto:lac-discuss-es at atlarge-lists.icann.org 
<mailto:lac-discuss-es at atlarge-lists.icann.org> &gt;


 Subject: [lac-discuss-en] Re: [ALAC-Announce] ICANN News Alert - ICANN Seeks 


 Public Comment on Data Retention RAA 2013 Specification and Data Elements 
 Legitimate Purposes for Collection and Retention 


 Colleagues, 


 called Annex may have significant legal implications in our 
 region. Let us summon experts in protection of personal data and other 
 issues related to data retention (Computational forensics, law 
 telecommunications, Civil Marco in the case of Brazil) to 
 form a opininslida, if there is enough interest. 


 Alejandro Pisanty 




 --------------------------- 
     Dr. Alejandro Pisanty 
 UNAM Faculty of Chemistry 
 3000 University Avenue, 04510 Mexico DF Mexico 






 +52-1-5541444475 <tel:%2B52-1-5541444475> FROM ABROAD


 +525541444475 <tel:%2B525541444475> SMS +525541444475 FROM MEXICO 
<tel:%2B525541444475>
 Blog: http://pisanty.blogspot.com 
 LinkedIn: http://www.linkedin.com/in/pisanty 
 Join the LinkedIn group UNAM, 
 http://www.linkedin.com/e/gis/22285/4A106C0C8614 
 Twitter: http://twitter.com/apisanty 
 ---- &gt;&gt; Join ISOC Mexico, http://www.isoc.org 
 . . . . . . . . . . . . . . . . 


 ________________________________________ 
 From: alac-announce-bounces at atlarge-lists.icann.org 
<mailto:alac-announce-bounces at atlarge-lists.icann.org>


<mailto:alac-announce-bounces at atlarge-lists.icann.org 
<mailto:alac-announce-bounces at atlarge-lists.icann.org> &gt; 
 [Alac-announce-bounces at atlarge-lists.icann.org 
<mailto:alac-announce-bounces at atlarge-lists.icann.org>
<mailto:alac-announce-bounces at atlarge-lists.icann.org 
<mailto:alac-announce-bounces at atlarge-lists.icann.org> &gt;] On behalf of 
 ICANN 
 At-Large 
 Staff [staff at atlarge.icann.org <mailto:staff at atlarge.icann.org>
<mailto:staff at atlarge.icann.org <mailto:staff at atlarge.icann.org> &gt;] Sent


 on: Friday, March 21, 2014 
 20:00 
 To: ALAC-Announce at atlarge-lists.icann.org 
<mailto:ALAC-Announce at atlarge-lists.icann.org>


<mailto:ALAC-Announce at atlarge-lists.icann.org 
<mailto:ALAC-Announce at atlarge-lists.icann.org> &gt; 


 Subject: [ALAC-Announce] ICANN News Alert - ICANN Seeks Public Comment on 
 RAA 2013 Specification Data Retention Data Elements and Legitimate Purposes 
 for Collection and Retention 


 [Http://www.icann.org/images/gradlogo_bow.jpg] <http://www.icann.org/>
 News Alert 


 http://www.icann.org/en/news/announcements/announcement-3-21mar14-en.htm 


 ________________________________ 
 ICANN Seeks Public Comment on 2013 RAA Data Retention Data Specification 
 Elements and Legitimate Purposes for Collection and Retention 


 21 March 2014 


 ICANN has-been in discussions with a number of Registrars Regarding data 
 retention requests waiver (&quot;Waiver Requests&quot;) submitted under the 2013 
 Registrar Accreditation Agreement (the &quot;2013 RAA&quot;).Some Registrars are 
 seeking an exemption from Un certain collection and / or retention requirements 
 under the Data Retention Specification (the &quot;Specification&quot;) of the 2013 
 RAA. Section 2 of the Data Retention Specification sets forth requirements 
 Regarding the written materials to register must submit in support of its 
 good faith determination That the collection and / or retention of any data 
 element specified in the Specification Violates applicable law, and Provides 
 That Following notice to ICANN of the Waiver Request, ICANN and the 
 Register applicable Shall discuss the matter in good faith in an effort to 
 reach a mutually acceptable resolution of the matter. An update on the 2013 
 RAA data retention and the waiver process can be found here: 
 http://blog.icann.org/2014/02/update-on-2013-raa-and-data-retention-waiver-p 


<http://blog.icann.org/2014/02/update-on-2013-raa-and-data-retention-waiver- 
<http://blog.icann.org/2014/02/update-on-2013-raa-and-data-retention-waiver- 
 process /&gt; 
 process /&gt; 


 rocess /


 ICANN staff Understands That data Should be Treated in Accordance with 
 applicable data protection laws, que Generally permit gathering and 
 personnel retention of data for legitimate purpose (s). ICANN Also Understands 
 That the law may vary from country to country as to (i) what is Considered to 
 legitimate purpose, (ii) Whether the personnel data is adequate, relevant and 
 not excessive in relation to the legitimate purpose for Which They are 
 collected and (iii) how long for Un Certain data elements May be Retained. In 
 other words, what is Considered a legitimate purpose for collection of 
 Un certain data in one country May not be Considered a legitimate purpose in 
 another country.


 During ICANN's discussions in an effort to reach a mutually acceptable 
 resolution of the matter, some have Requested That ICANN Registrars (a) 
 AMclarify and better define Un certain data elements in the Data Described 
 Retention Specification Maintain That the Registrars are not Clearly 
 defined; and (b) describes Potentially legitimate ministering purposes for collection and 
 retention of each data element That would help Provide guidance for 
 Both Whether Registrars Such elements as to Lawfully May be collected, and, 
 if so, for how long Such elements Lawfully Might be Retained. 


 In response to requests from some These Registrars, ICANN is posting for 
 seeking public comment a document to what is meant by AMclarify Un certain data 
 elements Described in the Specification and Describing Data Retention 
 Potentially legitimate ministering purposes for collection and retention of Those data 
 elements. That document can be found 
 here <http://www.icann.org/en/resources/registrars/raa/draft-data-retention-s  


<http://www.icann.org/en/resources/registrars/raa/draft-data-retention-spec- 
<http://www.icann.org/en/resources/registrars/raa/draft-data-retention-spec- 
 elements-21mar14-en.pdf&gt; 
 elements-21mar14-en.pdf&gt;


 Breast-elements-21mar14-en.pdf&gt; [PDF, 116 KB]. The document will be posted for 
 a period of thirty (30) days to seek feedback and input from the community 
 on (i) Whether the data elements are Appropriately described, (ii) Whether 
 ministering purposes cited for the collection and retention are Appropriate and 
 legitimate, and (iii) Whether there are other legitimate Potentially 
 ministering purposes for collection and retention of data Such elements. After the 
 thirty (30) day period has expired Following this posting, ICANN will 
 Consider all feedback and input received in Connection with Ongoing ICANNs 
 discussions to reach a mutually acceptable resolution of Waiver Requests. In 
 the interim, ICANN will continue its Ongoing discussions to reach a mutually 
 acceptable resolution of Waiver Requests with Single Registrars With the 
 additional goal of Granting Waiver Requests as and when to Appropriate. 


 A public comment period will REMAIN open until 11:59 p.m. PDT / California, 21 
 April 2014. Public comments will be available for consideration by ICANN 
 ICANN staff and the Board.


 * Comments can be posted to: 
 comments-retention-21mar14 at icann.org 
<mailto:comments-retention-21mar14 at icann.org>
<mailto:comments-retention-21mar14 at icann.org 
<mailto:comments-retention-21mar14 at icann.org> &gt; 


<mailto:comments-retention-21mar14 at icann 
<mailto:comments-retention-21mar14 at icann>


<mailto:comments-retention-21mar14 at icann 
<mailto:comments-retention-21mar14 at icann> &gt; 
 . Org&gt; 
 * Comments can be viewed at: 
 http://forum.icann.org/lists/comments-retention-21mar14/ 


 _______________________________________________ 



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