[Gnso-ppsai-pdp-wg] For your review - updated template Cat B - question 2

Tue Mar 18 02:58:52 UTC 2014

Hi All,
I agree with Michele and James as well. A lack of response to a reminder 
notice is hardly a indicator of problems or issues. As Michele noted, 
people respond if they need to update information -- and the annual 
reminder triggers action in those who have recently moved or changed 
office locations. People respond when there is a problem, but not when 
all is well.

I thought we had agreed as a group to stick closely to the 2013 RAA 
requirements, perhaps with a new overlay for p/p providers to reach out 
to their customers once a year as well. I agree with the summary that 
"Non-delivery or error  messages would then trigger reverification" -- 
but not a mere lack of response.

Requiring affirmative response to a mere notification is untold extra 
work for registrants and registries - and unneeded work as well since 
the Nominet study and reported experience indicate that p/p contact data 
is more accurate, not less. It will create confusion, frustration and 
disruption.

Best and looking forward to our call tomorrow,
Kathy

> I cannot agree with this.
>
> Just because somebody does not reply to an annual email does not mean 
> anything and expecting registrars or proxy / privacy providers to do 
> anything extra based on a lack of response is completely unreasonable.
>
> If there's a bounce or any other indication that the contact details 
> are invalid then let the 2013 RAA standards apply -- if any.
>
> But expecting registrars or privacy / proxy providers to do extra 
> validation simply because a customer hasn't responded to an annual 
> whois data reminder simply will not fly.
>
> We send out thousands of these reminders every year. Only a tiny 
> percentage of our clients ever reply to them -- and if their details 
> haven't changed why on earth would they have to?
>
> Regards
>
>
> Michele
>
> --
>
> Mr Michele NeylonRequiement
>
> Blacknight Solutions
>
> Hosting & Colocation, Domains
>
> http://www.blacknight.co/
>
> http://blog.blacknight.com/
>
> http://www.technology.ie
>
> Intl. +353 (0) 59  9183072
>
> Locall: 1850 929 929
>
> Direct Dial: +353 (0)59 9183090
>
> Fax. +353 (0) 1 4811 763
>
> Twitter: http://twitter.com/mneylon
>
> -------------------------------
>
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business 
> Park,Sleaty
>
> Road,Graiguecullen,Carlow,Ireland Company No.: 370845
>
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] *On Behalf Of *Valeriya 
> Sherman
> *Sent:* Monday, March 17, 2014 8:09 PM
> *To:* Metalitz, Steven; 'Williams, Todd'; Marika Konings; 
> gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template 
> Cat B - question 2
>
> I, Jim Bikoff, David Heasley, and Griffin Barnett agree with Todd's 
> assessment:
>
> Contact information that is ultimately revealed is valuable only if it 
> is accurate.
>
> The validation/verification requirements should be consistent with the 
> 2013 RAA requirements, but should go above and beyond 
> those requirements to ensure the accuracy of contact information.
>
> Registrars already send an annual Whois Data Reminder Policy 
> notification to registrants, reminding them to provide accurate and 
> up-to-date information.
>
> Similarly, the privacy/proxy customer's contact information should be 
> verified upon initial registration of the domain name (either by the 
> registrar or the Privacy/Proxy Service Provider) and periodically 
> thereafter by automated annual email re-verification notifications 
> that require an affirmative response by the P/P customer.  Absence of 
> a response would trigger a follow-up, reminding the privacy/proxy 
> customer to provide accurate and up-to-date information.
>
>
> Regards,
>
> Valeriya Sherman
> Silverberg, Goldman & Bikoff, L.L.P.
> 1101 30th Street, N.W.
> Suite 120
> Washington, D.C. 20007
> Tel 202.944.2330
> Cell 303.589.7477
> vsherman at sgbdc.com <mailto:vsherman at law.gwu.edu>
>
> ------------------------------------------------------------------------
>
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>[gnso-ppsai-pdp-wg-bounces at icann.org] 
> on behalf of Metalitz, Steven [met at msk.com]
> *Sent:* Monday, March 17, 2014 6:13 AM
> *To:* 'Williams, Todd'; Marika Konings; gnso-ppsai-pdp-wg at icann.org 
> <mailto:gnso-ppsai-pdp-wg at icann.org>
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template 
> Cat B - question 2
>
> I agree with Todd's characterization of the status of this discussion, 
> and that the questions he highlights are still open.
>
> Another aspect of the second question below is how the p/p service 
> provider should handle situations in which the contact information 
> supplied by the customer cannot be verified. In the parallel situation 
> involving non-proxy registrations, the RAA specification calls either 
> for suspension of the registration, or "manual verification," which is 
> not defined. How should this apply in the p/p service scenario?
>
> Steve Metalitz
>
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] 
> *On Behalf Of *Williams, Todd
> *Sent:* Friday, March 14, 2014 4:53 PM
> *To:* Marika Konings; gnso-ppsai-pdp-wg at icann.org 
> <mailto:gnso-ppsai-pdp-wg at icann.org>
> *Subject:* Re: [Gnso-ppsai-pdp-wg] For your review - updated template 
> Cat B - question 2
>
> Thanks Marika.  I missed part of the call on Tuesday where this may 
> have been discussed, but I don't see how the draft preliminary 
> recommendation follows from the attached Word document, insofar as it 
> concludes that p/p customer data should be validated and verified in a 
> manner consistent with the requirements outlined in the 2013 RAA.  I 
> thought the current posture was that the WG has basically agreed to 
> the 2013 RAA requirements as a floor, but that there was not yet 
> agreement on: 1) whether validation/verification requirements should 
> go beyond the 2013 RAA; and 2) if so, how.
>
> On the first question (2013 RAA vs. "more"), it appears that more of 
> the responses in the attached argue for "more" than not.  That also 
> seems to have been an open topic in our email threads (see attached). 
> Just to reiterate from that thread, the basic argument on the "more" 
> side (which I agree with) is that in order to partially offset the 
> delay that will inevitably occur when accessing p/p data, the "more" 
> should consist of whatever reasonable validation/verification steps 
> can be taken to increase the likelihood  that the information 
> ultimately obtained will be accurate enough to facilitate contact.  I 
> suppose that if we ultimately settle on a "reveal" procedure that is 
> essentially instantaneous in certain cases (once we get to discussing 
> "reveal" procedures), that may mitigate this concern.  But absent 
> assurances on that point, I would think we need to address it.
>
> On the second question: the attached appears to include multiple 
> proposals as to what may or may not ultimately comprise the "more" 
> (/e.g./, email _and_ phone vs. or; periodic/annual re-verification vs. 
> re-verification with information suggesting the contact information is 
> incorrect; etc.).  Have we debated the relative merits of those?  Are 
> some more likely to be effective than others?  I have my thoughts, but 
> I'm curious to hear what everybody else thinks.
>
> Thanks all.
>
> Todd.
>
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] 
> *On Behalf Of *Marika Konings
> *Sent:* Thursday, March 13, 2014 7:04 AM
> *To:* gnso-ppsai-pdp-wg at icann.org <mailto:gnso-ppsai-pdp-wg at icann.org>
> *Subject:* [Gnso-ppsai-pdp-wg] For your review - updated template Cat 
> B - question 2
>
> Dear All,
>
> Following our call earlier this week, please find attached the updated 
> template for Category B -- question 2. To facilitate your review, I've 
> posted below the draft preliminary recommendation in which we've aimed 
> to capture the conversation to date taking into account the language 
> of the Whois Accuracy Specification Program of the 2013 RAA. If you 
> are of the view that this does not accurately capture the WG's view to 
> date and/or have specific suggestions for changes / edits, please 
> share those with the mailing list. Also, if there are any other issues 
> that need to be addressed in relation to this question and/or the 
> preliminary recommendation, please share those as well.
>
> Best regards,
>
> Marika
>
> *Draft Preliminary Recommendation -- Category B -- question 2 (Should 
> ICANN-accredited privacy/proxy service providers be required to 
> conduct periodic checks to ensure accuracy of customer contact 
> information; and if so, how?)*
>
> The WG recommends that proxy and privacy customer data be validated 
> and verified in a manner consistent with the requirements outlined in 
> Whois Accuracy Specification Program of the 2013 RAA. The WG 
> furthermore agrees that in the cases where validation and verification 
> of the P/P customer data was carried out by the registrar, 
> reverification by the P/P service of the same, identical, information 
> should not be required.
>
> Similar to ICANN's Whois Data Reminder Policy 
> (http://www.icann.org/en/resources/registrars/consensus-policies/wdrp), the 
> P/P provider should be required to inform the P/P customer annually of 
> his/her requirement to provide accurate and up to date contact 
> information to the P/P provider. If the P/P provider has any 
> information suggesting that the P/P customer information is incorrect 
> (such as P/P service receiving a bounced email notification or 
> non-delivery notification message in connection with compliance with 
> data reminder notices or otherwise) for any P/P customer, the P/P 
> provider must verify or re-verify, as applicable, the email 
> address(es). If, within fifteen (15) calendar days after receiving any 
> such information, P/P service does not receive an affirmative response 
> from the P/P customer providing the required verification, the P/P 
> service shall verify the applicable contact information manually.
>
>
>
> _______________________________________________
> Gnso-ppsai-pdp-wg mailing list
> Gnso-ppsai-pdp-wg at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-ppsai-pdp-wg

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/gnso-ppsai-pdp-wg/attachments/20140317/ca145f52/attachment-0001.html>