GNSO-Approved RAA Amendments

[<Andreas.Bartels@xxxxxxxxxx>]

According to No. 3.14 "Registrar Audits", ICANN is allowed to disclose
Registrar confidential information on the basis of an ICANN
specification or policy.

It is not specified what "Registrar confidential information" is. Even
customer data in a wide sense is registrar confidential information. If
you intend to disclose information concerning customer data you would
need to specify in advance which information you would like to disclose
- and not later in a specification or policy. 

We see the need to have a transparent registrar audit by ICANN. On the
other hand publishing confidential information is a sensitive issue and
should respect national laws and especially data protection laws - don't
forget that you have many registrars outside the US where laws in some
areas are stricter.

We would appreciate it if the term "Registrar confidential information"
is described in more detail and the publishing of  "confidential"
information respects all applicable laws.

Best regards,

Andreas Bartels

Deutsche Telekom AG