[RDS-WHOIS2-RT] Data Accuracy subgroup draft report

Fri May 25 11:53:19 UTC 2018

Regarding Section 3.2, I am a bit puzzled why no reference at all is 
made to a significant qualifier included in Rec 6. Rec 6 only refers to 
reducing the occurrence of the accuracy groups of Substantial Failure 
and Full Failure (of contactibility of the contact). In other words, if 
there is a partial inaccuracy, this would not even be covered by the 
recommendation if sufficient contactibility is maintained by the 
remaining contact points. WHOIS ARS does not make such a differentiation 
either, and instead goes beyond the recommendation as it merely looks 
for any error in the data regardless of whether the remaining data 
provides for sufficient contactibility. The data from the ARS would have 
to be analyzed in more significant detail before making the 
determination of whether the recommendation was implemented. I also am 
not convinced that the observations under 3.2 are fit to match the 
recommendation, and some are baseless speculation:

1) This may very well be the case, but eneral improvement of the whois 
data is not what the recommendation is about. The recommendation is 
about achieving a certain level of accuracy, not total accuracy as the 
ARS is designed for.

2) We should not speculate on causes for reasons of why the numbers are 
what they are. Accordingly, the entire second paragraph should be removed.

3) Again, the inaccurate rate is of no importance in the contect of the 
recommendation. The only rate of concern would be that of inaccuracies 
that would be considered as Substantial and Full Failure of 
contactibility of the contact. Therefore this observation has no 
relevance to the recommendation as it stands.

4) Instead of seldom, I would use the term "very rarely, and only in the 
first cycle" to correctly reflect the numbers. Four cases of breach 
notices out of 2,688 tickets is statistically irrelevant.

With regard to section 3.5, I fully disregard with the phrasing of the 
statement in section 4 that refers to "... if the WDRP were fully 
enforced...". We have no reason to believe that at this time this policy 
is not fully enforced and followed by registrars merely because of a 
report ICANN issued in 2004, especially as the followig section points 
out that we do not have reliable data from the compliance audit program. 
We must look at the situation today and if we have no data on that, we 
cannot make such a statement. I therefore suggest to strike the entire 
last paragraph of section 4. If anything, we should ask for compliance 
to provide better and more detailed data.

Further, the recommendation focusses on the impact of these messages, 
not on the observance of the policy by contracted parties, so the fifth 
paragraph focussing on registrar compliance misses that point entirely 
and should be removed. I agree with the assessment that rec 9 has not 
been implemented though.

4.0-4.5 This section should again loses focus of the actual content of 
the recommendations to improving contactibility, not overall accuracy. 
We should therefore rephrase this section accordingly. Instead of 
"accuracy" and "reliability" we should use instead the terminology of 
sufficient contactibility, substantial and full failure.

4.2. What is the basis for this belief? As the ARS program took great 
lengths to create a significant sample size, its results regarding 
accuracy as a percentage should have some statistical relevance 
regarding the overall inaccuracy. Also, inaccuracies should be graded by 
the standards laid down in the recommendations. Insignificant 
inaccuracies that do not affect contactibility were still reported by 
the ARS program and included in the statistics, but play no role in the 
evaluation of the implementation of the recommendations. For example, 
many ARS compliance reports we received were for formatting errors where 
the data in the WHOIS, while accurate, did not match the format 
prescribed by the RAA, was entered in the wrong field, etc. Such 
inaccuracies do not normally affect contactibility.

4.3 I disagree with the section headline. The contractual compliance 
report to the contrary demonstrates proper enforcement of these 
obligations as they demonstrate the enforcement actions taken upon 
discovery of a deficiency. I also would argue for the removal of the 
section regarding Avalanche, since it is anecdotal at best and has no 
implication on compliance as the obligations are phrased in a way to 
allow multiple venues and methods of verification.

4.4. seems to be missing a word in the headline.
Also, as the the privacy proxy service take the role of the registrant 
in the public whois, on the accuracy of its own contact data should be 
of relevance for whois accuracy. Any issues with inaccuracies of the 
underlying data do not factor into the recommandations as issue for this 
subgroup. Instead any discussions of underlying data accuracies should 
be restricted to the privacy proxy subgroup.

4.5. As inaccuracy of whois is not at issue, this entire section would 
need reworking. I also do not agree with its conclusion that the 
measures are not sufficient to fulfill the targets of the recommendations.

I also reject the assumption of the perception of non-compliance by 
registrars with their obligations. From my own experience, most 
inaccuracy reports received are not preventable by the measures required 
by the RAA. A record may be fully validatable and verifyable, yet still 
be incorrect. For example, an address may be perfectly formatted in 
accordance with the requirements, thus passing every required 
validation, yet still be incorrect due to the street not existing or 
being the address of someone else. I therefore strongly suggest removing 
the last paragraph of section 1 of 4.5.

Am 25.05.2018 um 12:40 schrieb SUN Lili:
>
> Dear all,
>
> Sorry for the late submission.
>
> Please refer to attached the revised version of the Data Accuracy 
> subgroup draft report, which incorporated the discussion of 2^nd F2F 
> meeting and answers to the follow up questions on Data accuracy and 
> Compliance from ICANN.
>
> As to the proposed recommendations, I’ll reflect in Compliance 
> subgroup draft report.
>
> Thanks,
>
> Lili
>
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