At-Large Workspace: Proposed gTLD-Registration Data Access Protocol (RDAP) Profile
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FINAL VERSION SUBMITTED (IF RATIFIED)
The final version to be submitted, if the draft is ratified, will be placed here by upon completion of the vote.
FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.
DRAFT SUBMITTED FOR DISCUSSION
The first draft submitted will be placed here before the call for comments begins. The Draft should be preceded by the name of the person submitting the draft and the date/time. If, during the discussion, the draft is revised, the older version(S) should be left in place and the new version along with a header line identifying the drafter and date/time should be placed above the older version(s), separated by a Horizontal Rule (available + Insert More Content control).
Comments
You're right Holly.
When we discussed RDAP in the EWG, the most compelling reason it was reported favourably was the capability vested in the protocol to process multiple attributes in decision-making on access; who, what, how and how long. That ICANN chose to endorse a less-than-ideal implementation is regrettable. But that is not a disability of the protocol. We should record that, along with the political decision.
-Carlton
To be clear, the Temp Spec does not require gated access. It requires that contracted parties respond to requests, not necessarily through an automated protocol.
The EPDP policy may need gated access if we can all agree to do so. Without lowering contracted parties liabilities if they rely on such access and are then cited for a breach of GDPR, it is unlikely, in my mind, that we will come to such an agreement.
I have asked the Technical Issues Working Group.
https://atlarge-lists.icann.org/pipermail/technical-issues/2018-September/000397.html
In my opinion, it collects assertive suggestions for the implementation of RDAP. Therefore, I support the comment as redacted.
We need technical advice on this issue. From my non-technical perspective, therefore: When the RDAP was developed, included the functionality to provide gated access to registration data. When ICANN adopted thee protocol however, the functionality to provide gated access was optional - not required. The explanation was that, at that stage - and still the case - there is no policy now in force in ICANN to require gated access to registration data. Given that the Temporary Spec requires gated access and any final ICANN acopted policy will certainly require gated access, the functionality of gated access should be a required feature of the RDAP.