[Gdd-gnso-ppsai-impl] [Response Requested by 6 January] Draft Section I PP Policy, Illustrative 12-month timeline

Fri Jan 6 22:10:15 UTC 2017

Thanks, Amy and colleagues.  I agree with Theo this is a good start.

Here are my responses to some of Amy's MS Word comments.

A general observation is that any definitional issues should not be discussed in the abstract but in connection with the implementing the substantive PDP recommendation to which they apply.

AB 1:  I agree with those who have said that the "establish or maintain a physical office" criterion is suitable for discussion by the LEA framework group (consistent with the general observation above).  Though I would ask - since this language is taken verbatim from the RAA, have problems arisen in that context in the past 4 years that suggest it needs to be addressed here at all?

AB 2:  As I recall there was discussion in the PDP WG about whether "reasonable period of time" could be further defined, but in any case, this should be discussed when we get to obligations on relay/forwarding.

AB 3:  Isn't the definition of customer missing a few words :  "the licensee or beneficial owner of a registered domain name registered using a privacy service or proxy service"?

AB 4:  Agree that "or entity" could be deleted but since not everyone references back to the definitions, is there any downside to keeping it?

AB 5:  Agree, perhaps the phrase "and/or" would be useful here.

AB 6: As noted, this is a good starting point for discussion on what registrar should do when becoming aware of non-accredited services.

The second sentence of Paragraph E (i)  does not track the Report and could create confusion as drafted.  I suggest the following revision of E.1:

    This Policy does not distinguish between Proxy Service Customers who are engaged in commercial or non-commercial activity, and does not require any accredited privacy or proxy service provider to do so.

Without this change, a registrant who wishes to use a proxy registration to carry out commercial activities could question the accreditation status of a provider who chooses not to allow such uses within its service (i.e., the registrant is not being treated "equally").

Steve Metalitz

From: gdd-gnso-ppsai-impl-bounces at icann.org [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of theo geurts
Sent: Tuesday, January 03, 2017 11:28 AM
To: gdd-gnso-ppsai-impl at icann.org
Subject: Re: [Gdd-gnso-ppsai-impl] [Response Requested by 6 January] Draft Section I PP Policy, Illustrative 12-month timeline

Hi Amy,

This is looking good for a first draft.

At first glance section C3 seems to carry some operational issues and creates some room for potential abuse. But nothing pressing for now.

Best,

Theo Geurts | Compliance & Policy Officer

Realtime Register B.V.

Ceintuurbaan 32A

8024 AA - ZWOLLE - The Netherlands

T: +31.384530759

F: +31.384524734

U: www.realtimeregister.com<http://www.realtimeregister.com>

E: legal at realtimeregister.com<mailto:legal at realtimeregister.com>
On 3-1-2017 14:34, Amy Bivins wrote:
Hello, All,

This is a  reminder that we are requesting your feedback on these items no later than this Friday, 6 January, so that we can plan for discussion at our next meeting, scheduled for 10 January 2017.

Best,
Amy

Amy E. Bivins
Registrar Policy Services 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>

From: gdd-gnso-ppsai-impl-bounces at icann.org<mailto:gdd-gnso-ppsai-impl-bounces at icann.org> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Amy Bivins
Sent: Friday, December 23, 2016 11:39 AM
To: gdd-gnso-ppsai-impl at icann.org<mailto:gdd-gnso-ppsai-impl at icann.org>
Subject: [Gdd-gnso-ppsai-impl] [Response Requested by 6 January] Draft Section I PP Policy, Illustrative 12-month timeline

Hello, All,

I have a few developments to share with you. Items 3 and 4 require action from you, so please review this message carefully.

First, ICANN will be formally announcing to accredited registrars today that the expiration date of the 2013 RAA Specification on Privacy and Proxy Registrations is extended to 1 January 2018.

Second, the new LEA subgroup page is up the wiki, https://community.icann.org/display/IRT/Subgroup%3A+Law+Enforcement+Authority+Issues<https://community.icann.org/display/IRT/Subgroup%3A+Law+Enforcement+Authority+Issues>. The subgroup likely won't meet until shortly before ICANN58, but I am glad that so many of you have signed up and that we have the subgroup ready when there is a proposal ready to discuss. I'll continue to share all information I have about this effort with you (this effort should be officially kicked off with the PSWG in early January).

Third, a first draft of Section 1 of the Privacy and Proxy Service Provider Accreditation Provider is attached and ready for your review. We will be discussing this on our 10 January call. Please provide your initial feedback to the list no later than your EOD 6 January, so that we can plan for how to allocate time for this topic on the next call.

Fourth, pursuant to a request on the 13 December 2016 call, ICANN has prepared an illustrative timeline showing our best estimate for how we could attempt to compress the existing project plan into a one-year timeline to coincide with the new 1 January 2018 expiration date of the interim 2013 RAA Specification.

Please note:

*         This is ICANN's best estimate only. If the IRT wants to pursue this compressed timeline, this plan could shift and change along the way due to a variety of factors and dependencies, many beyond ICANN's (and the IRT's) control (for example, an additional deliverable on Transfer Policy requirements might need to be added to the project plan).

*         The distribution of this illustrative timeline is not an ICANN endorsement of this timeline. There could be significant impacts to the initial application process and account management infrastructure, at a minimum, to rolling out this program at this pace-impacts that might be seen as detrimental by some within the community. For example, it is unlikely that ICANN will have a portal/system in place to accept applications and for accredited services to manage their accounts by 1 January 2018, even if the final implementation can be announced as soon as October 2017.

*         Dates noted in the timeline should not be interpreted as a commitment by ICANN, as meeting each milestone will depend on a multitude of factors.

*         Moving along at this pace would require weekly meetings, at a minimum. IRT discussion on topics that must be decided upon each week would either (a) need to be time-limited, by some process (suggested time allotments in the illustrative example are for discussion purposes only), or (b) the IRT would likely need to have longer or multiple meetings during at least some weeks to stay on schedule and resolve the relevant topic(s).

*         Meeting this illustrative timeline would significantly impact the burdens placed on staff and IRT volunteers. This could have a significant impact on the costs required to implement this program.

*         We want to stress the importance of ensuring that the final program implementation is sound and delivers what the PDP WG intended. This cannot be sacrificed for speed's sake (though staff will do everything we can to be efficient managers of this process).

*         ICANN will require at least 6+ months to become operationally ready to process applications for accreditation after all program requirements are finalized.

With those cautions firmly in mind, ICANN commits to use all reasonable efforts to adhere closely to this proposed timeline if the IRT wants to pursue this path.

Please provide your feedback on this timeline no later than 6 January 2017. If the IRT would like to explore some compromise between the originally proposed timeline and this 12-month timeline, ICANN is also open to that (this exercise identified some areas where this timeline might be compressed with lesser impacts on overall burdens than the 12-month timeline attached).

Fifth, I have consulted internally regarding the appropriate day(s) for scheduling face-to-face meetings before ICANN58 (which was the most popular option in the Doodle poll, by one vote). The schedule is not set yet, so I apologize that the poll was premature. I will let you know as soon as I know what the approved date(s) for a day-long meeting prior to ICANN58 would be.

Finally, this is a reminder that ICANN offices are closed 24 December until 2 January. I hope that you all have a happy and healthy holiday season (for those who celebrate) and I look forward to working with you all in the new year.

Best,
Amy

Amy E. Bivins
Registrar Policy Services 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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