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

Tue Mar 18 09:59:51 UTC 2014

I am sad to say but the 2013 RAA does _nothing_ to guarantee acurate 
whois as long as the data makes sense and the email address does not 
bounce after the first feedback loop, the data is verified/validated 
with no guarantee that the address actually belongs to the registrant.

For example, on the pharmacy domains registered through our platform 
from time to time, what we see mostly are that most of them use 
individual data sets that are used for each individual registration, 
each set perfectly verifiable, 100% accurate, from individuals all 
around the globe who most likely do not have an inkling of the use of 
their data in these registrations.

> 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.
Incorrect, the 2013 RAA demands no such thing and neither should we. 
While whois reminder messages are sent, none of these messages require 
an affirmative response. Such a model would be customer-unfriendly and 
dangerous to any established business.

Volker

>
> 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 
> [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
> *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] *On Behalf Of *Williams, Todd
> *Sent:* Friday, March 14, 2014 4:53 PM
> *To:* Marika Konings; 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.
>
>
>
> _______________________________________________
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