[Gdd-gnso-ppsai-impl] Materials and questions for 24 January PP IRT Call

Mon Jan 23 18:28:00 UTC 2017

Hi Steve,

Thank you for your quick response and suggestion. This approach was not
considered-we started with the approach taken in the statement of registrar
accreditation policy, which includes Policy requirements that are further
developed in the RAA,
https://www.icann.org/resources/pages/policy-statement-2012-02-25-en#II.

However, that is not to say that we can't take this approach, and your
reasoning outlined below clearly explains the potential benefits. 

What do others on the list think? I will also raise this internally today
and hope to have some additional information to share with you tomorrow on
the call.

If we end up taking this approach and decide to significantly reduce this
section of the Policy, there are still many questions in the document that
we can discuss tomorrow to aid in our drafting of the first versions of the
contractual provisions for the IRT's review.

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

www.icann.org

From: gdd-gnso-ppsai-impl-bounces at icann.org
[mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Metalitz, Steven
Sent: Monday, January 23, 2017 1:06 PM
To: gdd-gnso-ppsai-impl at icann.org
Subject: Re: [Gdd-gnso-ppsai-impl] Materials and questions for 24 January PP
IRT Call

Hello Amy and colleagues, 

A threshold question regarding your draft of section II: 

I am not clear on your distinction between the level of specificity in the
document called "policy" and in the contract that accredited services would
be asked to sign. 

One approach would be for section II to read in its entirety: 

"Privacy and Proxy Service providers SHALL enter into and maintain in effect
Accreditation Agreements with ICANN that set out the terms and conditions of
accreditation.   The current standard Accreditation Agreement is attached as
Attachment A. "

There could be at least two advantages to this approach. First, we would
save the time required to set varying levels of specificity between the two
documents.  (For instance, as noted in your MS Word comment #9, deciding
whether we agree or disagree with your belief that the triggering
requirements for verification and reverification of customer information is
"more appropriately included in the contract" than in the policy.)  Second,
this would avoid the situation in which there might be perceived (or real)
discrepancies between the statement in this section of the Policy and the
actual terms of the Agreement to which providers would be subject.  In other
words, more efficiency for this IRT and less ambiguity and confusion once
the program is in place. 

Was this approach considered, and if so , why was it rejected?  

A variation on my suggestion would be for IRT to review a draft
accreditation agreement first, and then turn to whether any of its
provisions need to be summarized or specifically referenced in section II of
the policy document.  

Looking forward to your response.  Thanks.  

Steve Metalitz 

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: Sunday, January 22, 2017 2:17 PM
To: gdd-gnso-ppsai-impl at icann.org <mailto:gdd-gnso-ppsai-impl at icann.org> 
Subject: [Gdd-gnso-ppsai-impl] Materials and questions for 24 January PP IRT
Call

Dear Colleagues,

Attached are documents for discussion on Tuesday's (24 January, 15:00 UTC)
Privacy and Proxy Service Provider Accreditation Program IRT call: draft
Policy sections 2, 5, and 6. 

We will review as much of these documents as we can Tuesday, and continue
with them next week, if needed. The poll results show a clear preference for
weekly meetings, so we will be moving to that schedule-thank you for your
participation in the poll! A meeting reminder will be distributed on Monday.

I want to flag some of the questions we have for you on Section 2, as noted
in more detail in the attached:

1.       The Final Report in some cases uses the word "SHOULD."  ICANN org
requests the IRT's feedback on the PDP WG's intent in using the word (as
SHOULD is defined here: http://www.ietf.org/rfc/rfc2119.txt), and whether
"SHALL" was intended in any of these instances.

2.       With respect to data reminders, did the PDP WG intend for these
reminders to reference (a) any Customer information that appears in WHOIS,
(b) the underlying Customer data, or (c) both?

3.       With respect to data validation and verification, did the PDP WG
intend for the requirement to apply to (a) any Customer data, as relevant,
in WHOIS; (b) underlying Customer data, as relevant, or (c) both?
(Additional questions in document)

4.       Did the PDP WG intend for ICANN org to implement new requirements
for Privacy and Proxy Service providers to escrow and retain data, distinct
from the existing requirements in the RAA?

5.       Did the PDP WG intend for this implementation to create minimum,
mandatory criteria for all requests to Privacy and Proxy Service providers
(See draft Section 2.J)?

We will also seek your feedback on the level of detail that is being
proposed for the Policy versus the contract.

If you have any questions or want to begin to discussing these issues
on-list before the call, please feel free to do so. I look forward to
speaking with you on Tuesday.

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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