ICANN and the Data Quality Act: Part 6 - ICANN's Strategic Plan
The requirement that ICANN develop a Strategic Plan offers an important opportunity for achieving meaningful reform of the organization. The Strategic Plan is one of the key new ICANN duties contained in the most recent amendment to their Memorandum of Understanding (MOU) with the Department of Commerce. The MOU specifies in considerable detail the elements that ICANN is to include in the Plan including issues ranging from executive compensation to mechanisms for ICANN accountability. In that ICANN's preparation of the Plan is specified by the MOU and the Department has oversight responsibility for the Plan and other tasks ICANN performs under the MOU, the Strategic Plan is "sponsored" information and will be subject to the provisions of the Data Quality Act and implementing guidelines. The issue of the ICANN and the Data Quality have been extensively discussed in earlier parts of this series.

Key issues which ICANN is required to address in the Strategic Plan include:

• Review of administrative structures;
• Review of accountability mechanisms;
• Development and implementation of a financial strategy;
• Review and augmentation of ICANN's corporate compliance program, including auditing contracts for compliance; and
• Developing a collaborative outreach program to governments and other stakeholders.

Once published, the Strategic Plan, as well as additional information published pursuant to implementation of the Plan, would be subject to the Data Quality Act's Quality, Objectivity, Utility and Integrity standards. The applicable Data Quality standards are detailed by the Act's implementing guidelines from the White House Office of Management and Budget and the Department of Commerce's National Telecommunications and Information Administration. Under the Act, affected parties would have the right to seek and obtain correction of information in the Strategic Plan not meeting Data Quality standards.

ICANN's Strategic Plan was due by December 31, 2003. Specific dates were also established in the MOU for completion/implementation of the various tasks to be addressed by the Plan. To date, there is no indication from either ICANN or the Department of Commerce that ICANN has developed the Plan. Failure of ICANN to promptly publish their Strategic Plan, i.e. their non-compliance with the MOU, would demonstrate the need for substantially closer federal oversight of the organization.