Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
Dear GNSO Council,
NCSG submits the attached human rights–oriented input in response to the RDRS Standing Committee Final Report dated 19 August 2025. This submission addresses each of the seven recommendations with a view toward preserving users’ human rights, especially privacy, ensuring transparency and accountability, and preventing unintended harms that may arise from automation, overreach, or insufficient oversight.
We appreciate the Council’s continued engagement with the broader community and remain available to support further work toward rights-respecting evolution of the RDRS framework.
Throughout our comments, we underscore that registrars must not simply render requests. They should conduct a documented evaluation of the fundamental rights at stake — including privacy, freedom of expression, and due process, and provide a clear rationale for any decision to disclose the information. This is not only a best practice; it is necessary to ensure registrant rights are not subordinated to expediency or automation.
In closing, NCSG reiterates its unwavering commitment to privacy, accountability, and the protection of fundamental human rights. These are not optional add-ons, they must be the foundation of any system that mediates access (in any shape or form) to personal data. We call on the GNSO Council, the RDRS Standing Committee, and participating registrars to embed these principles with clarity, enforceability, and visibility in every procedural step.