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

Tue Mar 18 10:20:36 UTC 2014

I do not agree with this draft proposal for various reasons:

a) The obligations of the p/p provider should match those of the 
registrar the registration is performed under. In other words, the p/p 
provider should not be required to perform checks that would not be 
applicable to the registration as the sponsoring registrar is under a 
different RAA.

b) I disagree with the requirement for manual verification. The provider 
should have the option to bow out of the agreement as well.

c) The draft only uses verify, whereas the RAA differentiates between 
verification and validation. Any obligation to other service providers 
should match those of the sponsoring registrar.

d) Why should there be (re-)verification of the email address when a 
different data point is claimed to be incorrect? What purpose does that 
serve?

e) The recommendation should contain a carve-out that the obligation 
only applies if the reminder to the beneficial owner is not already sent 
by the registrar. No need to confuse registrants with duplicate reminders.

Volker

Am 17.03.2014 22:44, schrieb Marika Konings:
> Val, please note that the draft preliminary recommendation proposes 
> that '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'.
>
> Does that address your last point? If not, do you or any of the others 
> that have indicated that they agree with Todd's assessment have any 
> suggestions for additions / changes to the draft preliminary 
> recommendation that the WG could review and consider during its 
> meeting tomorrow?
>
> Best regards,
>
> Marika
>
> From: Valeriya Sherman <VSherman at sgbdc.com <mailto:VSherman at sgbdc.com>>
> Date: Monday 17 March 2014 21:08
> To: "Metalitz, Steven" <met at msk.com <mailto:met at msk.com>>, "'Williams, 
> Todd'" <Todd.Williams at turner.com <mailto:Todd.Williams at turner.com>>, 
> Marika Konings <marika.konings at icann.org 
> <mailto:marika.konings at icann.org>>, "gnso-ppsai-pdp-wg at icann.org 
> <mailto:gnso-ppsai-pdp-wg at icann.org>" <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, 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 
> <mailto:gnso-ppsai-pdp-wg-bounces at icann.org>] on behalf of Metalitz, 
> Steven [met at msk.com <mailto: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

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