[RDS-WHOIS2-RT] Compliance subgroup draft report

[Susan Kawaguchi]

Hello All,

After a meeting by the subgroup on Friday I have made revisions to the
subgroup report for discussion during our call on Monday.


   - Rec#1 - revise to read "enforced as required" to address Stephanie's
   comment on F2F#2
   - Rec#4 - incorporate into Outreach report existing recommendation 3.2
   as a specific example of desired outreach, and refer to the Outreach
   recommendation from Section 3.2.1.2 in Compliance report
   - Rec #5 - expand recommendation text to focus on compliance processes
   to encourage use of Bulk tool,
   - Rec #8 - refer to Bulk WHOIS tool when discussing possible sources of
   input to identify systemic abuse
   - Rec#7 - discuss clarified text for this Recommendation in plenary
   - To address Accuracy issue where accuracy of P/P registration data is
   not monitored and cannot be enforced, draft a new recommendation that P/P
   registration data providers must adhere to the current RAA requirements for
   verification and validation.
   - Raise as comments on Rec #11 subgroup report (Common Interface) for
   discussion in plenary call:

(1) As a result of GDPR implementation, RR and Ry interpretations may
result in different registration data returned  by WHOIS for the same
domain name (e.g., the Ry may redact data that the RR displays)

(2) Bulk data access has become less reliable (e.g., timeouts more frequent)


I also started a draft recommendation on accuracy in PP registrations


*Privacy and Proxy  registration data providers must adhere to the current
RAA requirements for verification and validation of the underlying
registrant data.  *

The following is from the PPSAI final report, I thought it may help in the
discussion.

P/P service providers should be required to inform the P/P service customer
annually of his/her requirement to provide accurate and up to date contact
information to the P/P service provider. If the P/P service provider has
any information suggesting that the P/P service customer information is
incorrect (such as the provider receiving a bounced email notification or
non-delivery notification message in connection with compliance with data
reminder notices or otherwise) for any P/P service customer, the provider
must verify or re-verify, as applicable, the email address(es). If, within
fifteen (15) calendar days after receiving any such information, the P/P
service provider does not receive an affirmative response from the P/P
service customer providing the required verification, the P/P service
provider shall verify the applicable contact information manually.


Susan
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