It is not likely that ORCID would be subject to US surveillance law requests highlighted in the Schrems II decision. Since ORCID is not an “electronic communication service provider” as defined under Section 50 USC § 1881(b)(4), it is not subject to the Foreign Intelligence Services Act (“FISA”). ORCID provides an online registry that is used to identify researchers from member organizations; as such, Section 702 under FISA would not apply to ORCID and its data.