[Gnso-ppsai-pdp-wg] Escrowing of Data by NON accredited P/P Providers and accredited Providers that are not already ICANN accredited registrars.

[Chris Pelling]

Afternoon all, 

Further to the F2F, I would further like to remind us all and put on record the escrowing of the underlying data of the registrant. Registrars whom are signed up to the 2009/2013 RAA have to escrow the underlying data of the registrant to an ICANN escrow provider, for example Iron Mountain, weekly, or in some cases depending on size of registrar - daily. 

Now with regards a lawyer whom will not be accredited if I am understanding the conversations correctly, how is the registrar to know that a registration from a lawyer is the registrant rather than the lawyer himself? Registrars now within ICANN audits have to stipulate the domains that the registrar owns, maybe lawyers and P/P providers should have the same caveat. I can see at some point these providers will fall within an audit that ICANN cooks up. 

Maybe it should be the case, that lawyers would have to enter into the same type of agreement with escrowing underlying data, and then, more importantly take an accredited P/P provider whom is NOT a registrar should also enter this same agreement with ICANN. 

The background and reasoning behind this was because of a registrar going "pop" leaves a total mess of registrants data and/or any data at all, the same can be said for lawyers who are disbarred, similar to the conversation in the F2F where we were told that lawyers who do not play by the rules would risk this, and there is a path to facilitate this if repeated incidents happen. 

I would, and probably like many registrars expect, no less than the same escrowing of underlying registrant data by any lawyer / accredited P/P provider that's not an ICANN accredited registrar. 

Lastly, to be frank if a lawyer does not wish to adhere to the P/P provisions that we have spent near 2 years debating and crafting, then what was the point of spending all this time in this PDP just to create tiers where some have to work within the rules and some don't. 

Kind Regards, 

Chris 

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