[Gdd-gnso-ppsai-impl] Answer to Compliance-related question raised on Tuesday's IRT call

[Amy Bivins]

Hello, All,

A question was raised on Tuesday's Privacy/Proxy IRT call about the auditing of PP data in registrar data escrow deposits (is there a check to conform that registrations listed as privacy-protected are included in the data escrow deposit, i.e., a completeness check?).

I checked with the Compliance team and have a bit more information to share with you.

Section 2.5 of the RAA Specification on Privacy and Proxy Registrations requires registrars to include P/P Customer contact information in Registration Data Escrow deposits, and the Registrar Data Escrow Specifications does allow for registrars to escrow both sets of data; but, there is nothing built into the existing DEA agreements that requires the DEA to follow a specific audit process that is unique to privacy and proxy registrations.  The DEA does follow-up with registrars to fix any issues when there are audit failures due to discrepancies in data, and sometimes, these could be due to failure of registrars to escrow both sets of data.

In the recent RFP that was published to identify one or more additional ICANN designated Registrar Data Escrow (RDE) agent(s), one of the requirements is that the proposals should account for privacy and proxy registration escrow requirements, https://www.icann.org/en/system/files/files/rfp-icann-agent-rde-services-17aug17-en.pdf

I hope this helps, but please let me know if you have any other clarifying questions/concerns.

Best,
Amy

Amy E. Bivins
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax:  +1 (202) 789-0104
Email: amy.bivins at icann.org<mailto:amy.bivins at icann.org>
www.icann.org<http://www.icann.org>

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