Registration Data Accuracy Scoping Team: Difference between revisions

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The '''Registration Data Accuracy Scoping Team''' (often shortened to the '''Accuracy Scoping Team''' or '''RDA Scoping Team''') was a GNSO group tasked with examining how the accuracy of gTLD registration data is defined, enforced, and measured in the post-[[General Data Protection Regulation|GDPR]] environment, and to advise the [[GNSO Council]] on possible next steps, including whether a [[Policy Development Process |Policy Development Process (PDP)]] or other mechanism was needed.<ref name="rda-formation">[https://gnso.icann.org/sites/default/files/file/field-file-attach/registration-data-accuracy-scoping-team-formation-instructions-09jul21-en.pdf ICANN GNSO: Registration Data Accuracy Scoping Team – Formation and Instructions]</ref>

The team conducted weekly meetings between October 2021 and 2022, producing a detailed report on enforcement and measurement of accuracy (Assignments #1 and #2). Its proposals were subsequently paused by the GNSO Council pending legal and contractual clarifications, and in August 2024 the Council decided not to proceed with the team’s main recommendations and not to restart the Scoping Team.<ref name="rda-motions-2022">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111103345/Motions%2B2022-11-17 ICANN Community: GNSO Council Motions – 17 November 2022]</ref> <ref name="rda-motions-2024">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111121679/Motions%2B2024-08-08 ICANN Community: GNSO Council Motions – 8 August 2024]</ref> ~~Its~~ findings and documentation ~~later informed~~ subsequent GNSO Council work on registration data accuracy, including the [[GNSO Council Registration Data Accuracy Small Team]].

The team conducted weekly meetings between October 2021 and 2022, producing a detailed report on enforcement and measurement of accuracy (Assignments #1 and #2). Its proposals were subsequently paused by the GNSO Council pending legal and contractual clarifications, and in August 2024 the Council decided not to proceed with the team’s main recommendations and not to restart the Scoping Team.<ref name="rda-motions-2022">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111103345/Motions%2B2022-11-17 ICANN Community: GNSO Council Motions – 17 November 2022]</ref> <ref name="rda-motions-2024">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111121679/Motions%2B2024-08-08 ICANN Community: GNSO Council Motions – 8 August 2024]</ref>

The Scoping Team's findings and documentation formed the background to subsequent GNSO Council work on registration data accuracy, including the establishment of the [[GNSO Council Registration Data Accuracy Small Team]]. <ref name="rda-smallteam-ws">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/178389005/Registration%2BData%2BAccuracy%2BSmall%2BTeam%2B2024-2025 ICANN Community: Registration Data Accuracy Small Team 2024–2025]</ref>

<ref name="rda-alac-liaison">[https://icann-community.atlassian.net/wiki/spaces/atlarge/pages/241074216 ICANN Community: GNSO Liaison Report – Developments, Concluded or Suspended Issues/PDPs/ODPs]</ref>

== Background ==

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In November 2020 the GNSO Council requested an ICANN org briefing on existing registration data accuracy requirements and programmes, and on how GDPR had affected enforcement of those requirements. ICANN org delivered this briefing, titled “Registration Data Accuracy Requirements and the European General Data Protection Regulation (GDPR)”, on February 26, 2021. The briefing suggested that it might be beneficial to develop, together with the GNSO Council, a framework for measuring accuracy under the new legal and technical conditions.<ref name="rda-briefing">[https://www.icann.org/en/system/files/correspondence/swinehart-to-fouquart-26feb21-en.pdf ICANN: ICANN Org Briefing – Registration Data Accuracy Requirements and the European GDPR]</ref>

== Membership ==

Membership of the Registration Data Accuracy Scoping Team was open to all GNSO Stakeholder Groups and Constituencies (SG/Cs), which were invited to appoint representatives and alternates. Other ICANN bodies, such as the GAC, the ALAC, and Security and the SSAC, were invited to nominate participants, and an ICANN Board liaison was assigned to follow the work.<ref name="rda-formation"></ref> <ref name="rda-gac-briefing-icann82"></ref>

The GAC, for example, nominated representatives from the European Commission and the United States to participate in the weekly deliberations starting in October 2021.<ref name="rda-gac-briefing-icann82"></ref> ICANN org staff from Policy and Contractual Compliance supported the team by providing briefings, legal analysis, and liaison with the ICANN Board.

The Scoping Team was chaired by [[Michael Palage]] (appointed from the ALAC).<ref name="rda-writeup"></ref> A call for Expressions of Interest for the chair role was circulated to the Supporting Organizations and Advisory Committees in November 2021.<ref name="rda-chair-eoi">[https://gnso.icann.org/sites/default/files/policy/2021/correspondence/gnso-council-to-soac-chairs-et-al-04nov21-en.pdf Call for Expressions of Interest for Chair of the Registration Data Accuracy Scoping Team (4 November 2021)]</ref>

== Formation ==

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In a December 1, 2022 letter to the GAC, ALAC, and SSAC, GNSO Council Chair [[Sebastien Ducos]] explained that, as a result of the motion, work on proposals requiring access to registration data was paused, and that the Scoping Team’s further engagement would depend on the outcome of ICANN org’s legal and contractual analyses and the completion of the DPA.<ref name="rda-ducos-2022"></ref>

== ICANN org Assessment ==

Pursuant to the Council’s 2022 resolution and earlier Board requests, ICANN org developed and assessed four possible scenarios for obtaining data to inform discussions on registration data accuracy. These scenarios were shared with the Scoping Team in May 2022 and later described in detail in ICANN org’s “Assessment of Registration Data Accuracy Scenarios”, delivered to the GNSO Council on October 19, 2023.

The four scenarios were:

# analysis of publicly available registration data for syntactic and operational accuracy (similar to the approach used in WHOIS ARS);

# a proactive Contractual Compliance audit of registrar compliance with validation and verification obligations under the RAA;

# analysis of a representative sample of full (public and non-public) registration data voluntarily provided by registrars to ICANN; and

# a voluntary registrar survey on accuracy-related practices.

ICANN org’s assessment concluded, among other points:<ref name="rda-assessment"></ref>

* Scenario 1 (public data analysis) would not provide meaningful insight because much of the relevant data is no longer publicly available after GDPR and the Temporary Specification.

* Scenario 2 (compliance audit) could be performed within existing contractual authority, and DPIA analysis indicated that a narrowly tailored audit could be carried out consistent with GDPR, but such an audit would primarily confirm compliance with existing obligations and would be resource-intensive (estimated cost of up to US$750,000 for a full-scale audit), without answering broader questions about identity-level accuracy.

* Scenario 3 (analysis of full data samples) raised significant legal concerns, with ICANN org indicating that it might lack a sufficient legal basis under GDPR to collect and process a representative sample of full registration data solely for an accuracy study, absent additional policy or contractual changes.

* Scenario 4 (voluntary registrar survey) could provide some insight into registrar practices but might yield statistically unrepresentative data if participation were limited, and would still face questions about the legal basis for processing certain data.

The report noted that none of the scenarios would confirm whether the registrant was who they claimed to be, which for some stakeholders formed part of their concept of “accuracy”. It proposed alternative steps, including leveraging historical and ongoing Contractual Compliance audit data and analyzing European ccTLD practices in the context of evolving legislative requirements such as the EU NIS2 Directive.<ref name="rda-assessment"></ref>

== Outcome and Developments ==

The GNSO Council discussed ICANN org’s Assessment of Registration Data Accuracy Scenarios at several meetings in late 2023 and 2024, deferring its consideration of the Scoping Team’s Recommendations #1 and #2 for additional six-month periods while key dependencies such as the DPA negotiations and related studies (including the [[Inferential Analysis of Maliciously Registered Domains|Inferential Analysis of Maliciously Registered Domains (INFERMAL)]] Study) remained outstanding.<ref name="rda-motions-2024"></ref> <ref name="rda-gac-briefing-icann82"></ref>

On August 8, 2024 the Council adopted a motion titled “Registration Data Accuracy Scoping Team Recommendations #1 and #2”, in which it:

* decided not to proceed with the Scoping Team’s Recommendations #1 (registrar survey) and #2 (registrar audit), citing the limitations identified in ICANN org’s Assessment of Registration Data Accuracy Scenarios;

* decided not to restart the Registration Data Accuracy Scoping Team at that time, due to limitations in processing data for the purpose of assessing accuracy; and

* reaffirmed the importance of registration data accuracy to the ICANN community and committed to continue discussing how best to move forward on the topic.<ref name="rda-motions-2024"></ref> <ref name="rda-motion-rec-08aug24">[https://gnso.icann.org/sites/default/files/policy/2024/vote-result/gnso-council-motion-recorder-08aug24-en.pdf ICANN GNSO: GNSO Council Motion Recorder – 8 August 2024]</ref>

By this point, the Registration Data Accuracy Scoping Team’s active work was effectively concluded.<ref name="rda-motions-2024"></ref> Its documentation, including the Formation and Instructions, meeting materials, and the “Deliberations and Findings for Assignments #1 and #2” report, remained as background for later GNSO Council efforts on accuracy, including the GNSO Council Registration Data Accuracy Small Team.<ref name="rda-alac-liaison"></ref> <ref name="rda-smallteam-ws"></ref>

== Members ==

* RrSG:

** [[Volker Greimann]]

** [[Roger Carney]]

** [[Sarah Wyld]]

** [[Owen Smigelski]] (alternate)

* RySG:

* [[Marc Anderson]]

* [[Sophie Hey]]

* [[Elizabeth Bacon]]

* [[Alan Woods]] (alternate)

* BC:

** [[Mason Cole]]

** [[Oluwatoba Obaniyi]]

* IPC:

** [[Scott Austin]]

** [[Marco Martinelli]]

** [[Matt Schwartz]] (alternate)

* ISPCP:

** [[Thomas Rickert]]

* SSAC:

** [[Steve Crocker]]

* GAC:

** [[Melina Stroungi]]

** [[Velimira Nemiguentcheva-Grau]]

** [[Kenneth Merrill]]

** [[Laureen Kapin]] (alternate)

** [[Susan Chalmers]] (alternate)

** [[Chris Lewis-Evans]] (alternate)

* ALAC:

* [[Alan Greenberg]]

* [[Michael Palage]] (Chair)

* NCSG

* [[Stephanie Perrin]]

* [[Manju Chen]]

* GNSO Council Liaison: [[Olga Cavalli]]

* ICANN org GDS Liaison: [[Brian Gutterman]]

* ICANN Board Liaison:

** [[Becky Burr]]

** [[Harald Alvestrand]]<ref>[https://icann-community.atlassian.net/wiki/spaces/AST/pages/103580899/4.+Members+mailing+list+archives ICANN Community: Accuracy Scoping Team Members & mailing list archives]</ref>

== References ==

@@ Line 1: / Line 1: @@
 The '''Registration Data Accuracy Scoping Team''' (often shortened to the '''Accuracy Scoping Team''' or '''RDA Scoping Team''') was a GNSO group tasked with examining how the accuracy of gTLD registration data is defined, enforced, and measured in the post-[[General Data Protection Regulation|GDPR]] environment, and to advise the [[GNSO Council]] on possible next steps, including whether a [[Policy Development Process |Policy Development Process (PDP)]] or other mechanism was needed.<ref name="rda-formation">[https://gnso.icann.org/sites/default/files/file/field-file-attach/registration-data-accuracy-scoping-team-formation-instructions-09jul21-en.pdf ICANN GNSO: Registration Data Accuracy Scoping Team – Formation and Instructions]</ref>
-The team conducted weekly meetings between October 2021 and 2022, producing a detailed report on enforcement and measurement of accuracy (Assignments #1 and #2). Its proposals were subsequently paused by the GNSO Council pending legal and contractual clarifications, and in August 2024 the Council decided not to proceed with the team’s main recommendations and not to restart the Scoping Team.<ref name="rda-motions-2022">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111103345/Motions%2B2022-11-17 ICANN Community: GNSO Council Motions – 17 November 2022]</ref> <ref name="rda-motions-2024">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111121679/Motions%2B2024-08-08 ICANN Community: GNSO Council Motions – 8 August 2024]</ref> Its findings and documentation later informed subsequent GNSO Council work on registration data accuracy, including the [[GNSO Council Registration Data Accuracy Small Team]].
+The team conducted weekly meetings between October 2021 and 2022, producing a detailed report on enforcement and measurement of accuracy (Assignments #1 and #2). Its proposals were subsequently paused by the GNSO Council pending legal and contractual clarifications, and in August 2024 the Council decided not to proceed with the team’s main recommendations and not to restart the Scoping Team.<ref name="rda-motions-2022">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111103345/Motions%2B2022-11-17 ICANN Community: GNSO Council Motions – 17 November 2022]</ref> <ref name="rda-motions-2024">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/111121679/Motions%2B2024-08-08 ICANN Community: GNSO Council Motions – 8 August 2024]</ref>
+The Scoping Team's findings and documentation formed the background to subsequent GNSO Council work on registration data accuracy, including the establishment of the [[GNSO Council Registration Data Accuracy Small Team]]. <ref name="rda-smallteam-ws">[https://icann-community.atlassian.net/wiki/spaces/gnsocouncilmeetings/pages/178389005/Registration%2BData%2BAccuracy%2BSmall%2BTeam%2B2024-2025  ICANN Community: Registration Data Accuracy Small Team 2024–2025]</ref>
+<ref name="rda-alac-liaison">[https://icann-community.atlassian.net/wiki/spaces/atlarge/pages/241074216 ICANN Community: GNSO Liaison Report – Developments, Concluded or Suspended Issues/PDPs/ODPs]</ref>
 == Background ==
@@ Line 10: / Line 13: @@
 In November 2020 the GNSO Council requested an ICANN org briefing on existing registration data accuracy requirements and programmes, and on how GDPR had affected enforcement of those requirements. ICANN org delivered this briefing, titled “Registration Data Accuracy Requirements and the European General Data Protection Regulation (GDPR)”, on February 26, 2021. The briefing suggested that it might be beneficial to develop, together with the GNSO Council, a framework for measuring accuracy under the new legal and technical conditions.<ref name="rda-briefing">[https://www.icann.org/en/system/files/correspondence/swinehart-to-fouquart-26feb21-en.pdf ICANN: ICANN Org Briefing – Registration Data Accuracy Requirements and the European GDPR]</ref>
+== Membership ==
+Membership of the Registration Data Accuracy Scoping Team was open to all GNSO Stakeholder Groups and Constituencies (SG/Cs), which were invited to appoint representatives and alternates. Other ICANN bodies, such as the GAC, the ALAC, and Security and the SSAC, were invited to nominate participants, and an ICANN Board liaison was assigned to follow the work.<ref name="rda-formation"></ref> <ref name="rda-gac-briefing-icann82"></ref>
+The GAC, for example, nominated representatives from the European Commission and the United States to participate in the weekly deliberations starting in October 2021.<ref name="rda-gac-briefing-icann82"></ref> ICANN org staff from Policy and Contractual Compliance supported the team by providing briefings, legal analysis, and liaison with the ICANN Board.
+The Scoping Team was chaired by [[Michael Palage]] (appointed from the ALAC).<ref name="rda-writeup"></ref> A call for Expressions of Interest for the chair role was circulated to the Supporting Organizations and Advisory Committees in November 2021.<ref name="rda-chair-eoi">[https://gnso.icann.org/sites/default/files/policy/2021/correspondence/gnso-council-to-soac-chairs-et-al-04nov21-en.pdf Call for Expressions of Interest for Chair of the Registration Data Accuracy Scoping Team (4 November 2021)]</ref>
 == Formation ==
@@ Line 80: / Line 91: @@
 In a December 1, 2022 letter to the GAC, ALAC, and SSAC, GNSO Council Chair [[Sebastien Ducos]] explained that, as a result of the motion, work on proposals requiring access to registration data was paused, and that the Scoping Team’s further engagement would depend on the outcome of ICANN org’s legal and contractual analyses and the completion of the DPA.<ref name="rda-ducos-2022"></ref>
+== ICANN org Assessment ==
+Pursuant to the Council’s 2022 resolution and earlier Board requests, ICANN org developed and assessed four possible scenarios for obtaining data to inform discussions on registration data accuracy. These scenarios were shared with the Scoping Team in May 2022 and later described in detail in ICANN org’s “Assessment of Registration Data Accuracy Scenarios”, delivered to the GNSO Council on October 19, 2023.
+The four scenarios were:
+# analysis of publicly available registration data for syntactic and operational accuracy (similar to the approach used in WHOIS ARS);
+# a proactive Contractual Compliance audit of registrar compliance with validation and verification obligations under the RAA;
+# analysis of a representative sample of full (public and non-public) registration data voluntarily provided by registrars to ICANN; and
+# a voluntary registrar survey on accuracy-related practices.
+ICANN org’s assessment concluded, among other points:<ref name="rda-assessment"></ref>
+* Scenario 1 (public data analysis) would not provide meaningful insight because much of the relevant data is no longer publicly available after GDPR and the Temporary Specification.
+* Scenario 2 (compliance audit) could be performed within existing contractual authority, and DPIA analysis indicated that a narrowly tailored audit could be carried out consistent with GDPR, but such an audit would primarily confirm compliance with existing obligations and would be resource-intensive (estimated cost of up to US$750,000 for a full-scale audit), without answering broader questions about identity-level accuracy.
+* Scenario 3 (analysis of full data samples) raised significant legal concerns, with ICANN org indicating that it might lack a sufficient legal basis under GDPR to collect and process a representative sample of full registration data solely for an accuracy study, absent additional policy or contractual changes.
+* Scenario 4 (voluntary registrar survey) could provide some insight into registrar practices but might yield statistically unrepresentative data if participation were limited, and would still face questions about the legal basis for processing certain data.
+The report noted that none of the scenarios would confirm whether the registrant was who they claimed to be, which for some stakeholders formed part of their concept of “accuracy”. It proposed alternative steps, including leveraging historical and ongoing Contractual Compliance audit data and analyzing European ccTLD practices in the context of evolving legislative requirements such as the EU NIS2 Directive.<ref name="rda-assessment"></ref>
+== Outcome and Developments ==
+The GNSO Council discussed ICANN org’s Assessment of Registration Data Accuracy Scenarios at several meetings in late 2023 and 2024, deferring its consideration of the Scoping Team’s Recommendations #1 and #2 for additional six-month periods while key dependencies such as the DPA negotiations and related studies (including the [[Inferential Analysis of Maliciously Registered Domains|Inferential Analysis of Maliciously Registered Domains (INFERMAL)]] Study) remained outstanding.<ref name="rda-motions-2024"></ref> <ref name="rda-gac-briefing-icann82"></ref>
+On August 8, 2024 the Council adopted a motion titled “Registration Data Accuracy Scoping Team Recommendations #1 and #2”, in which it:
+* decided not to proceed with the Scoping Team’s Recommendations #1 (registrar survey) and #2 (registrar audit), citing the limitations identified in ICANN org’s Assessment of Registration Data Accuracy Scenarios;
+* decided not to restart the Registration Data Accuracy Scoping Team at that time, due to limitations in processing data for the purpose of assessing accuracy; and
+* reaffirmed the importance of registration data accuracy to the ICANN community and committed to continue discussing how best to move forward on the topic.<ref name="rda-motions-2024"></ref> <ref name="rda-motion-rec-08aug24">[https://gnso.icann.org/sites/default/files/policy/2024/vote-result/gnso-council-motion-recorder-08aug24-en.pdf ICANN GNSO: GNSO Council Motion Recorder – 8 August 2024]</ref>
+By this point, the Registration Data Accuracy Scoping Team’s active work was effectively concluded.<ref name="rda-motions-2024"></ref> Its documentation, including the Formation and Instructions, meeting materials, and the “Deliberations and Findings for Assignments #1 and #2” report, remained as background for later GNSO Council efforts on accuracy, including the GNSO Council Registration Data Accuracy Small Team.<ref name="rda-alac-liaison"></ref> <ref name="rda-smallteam-ws"></ref>
+== Members ==
+* RrSG:
+** [[Volker Greimann]]
+** [[Roger Carney]]
+** [[Sarah Wyld]]
+** [[Owen Smigelski]] (alternate)
+* RySG:
+* [[Marc Anderson]]
+* [[Sophie Hey]]
+* [[Elizabeth Bacon]]
+* [[Alan Woods]] (alternate)
+* BC:
+** [[Mason Cole]]
+** [[Oluwatoba Obaniyi]]
+* IPC:
+** [[Scott Austin]]
+** [[Marco Martinelli]]
+** [[Matt Schwartz]] (alternate)
+* ISPCP:
+** [[Thomas Rickert]]
+* SSAC:
+** [[Steve Crocker]]
+* GAC:
+** [[Melina Stroungi]]
+** [[Velimira Nemiguentcheva-Grau]]
+** [[Kenneth Merrill]]
+** [[Laureen Kapin]] (alternate)
+** [[Susan Chalmers]] (alternate)
+** [[Chris Lewis-Evans]] (alternate)
+* ALAC:
+* [[Alan Greenberg]]
+* [[Michael Palage]] (Chair)
+* NCSG
+* [[Stephanie Perrin]]
+* [[Manju Chen]]
+* GNSO Council Liaison: [[Olga Cavalli]]
+* ICANN org GDS Liaison: [[Brian Gutterman]]
+* ICANN Board Liaison:
+** [[Becky Burr]]
+** [[Harald Alvestrand]]<ref>[https://icann-community.atlassian.net/wiki/spaces/AST/pages/103580899/4.+Members+mailing+list+archives ICANN Community: Accuracy Scoping Team Members & mailing list archives]</ref>
 == References ==