[Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
theo geurts
gtheo at xs4all.nl
Fri May 26 14:11:47 UTC 2017
I agree with Eric and Greg.
Theo
On 25-5-2017 19:12, DiBiase, Gregory via Gdd-gnso-ppsai-impl wrote:
>
> I won’t be able to make the call Tuesday, but I’d like to second
> Eric’s comments on two points:
>
> Regarding the annotated application:
>
> * start off the application with “Are you affiliated with an
> ICANN-accredited registrar?” for clarity and to help streamline.
>
> ·If applicant states to be affiliated with a registrar, ICANN will be
> able to quickly take that said group of answers and cross check with
> what should already be available from the accredited registrar provided.
>
> There should be some type of mechanism to confirm things like “same
> address as registrar” without having to fill out these fields all over
> again. An option for registrars to have their registrar information
> populated and simply change any fields that are different would be great.
>
> Regarding the reduction of requirements, I agree that Eric’s examples
> are not necessary for the p/p provider application.
>
> *From:*gdd-gnso-ppsai-impl-bounces at icann.org
> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] *On Behalf Of *Amy Bivins
> *Sent:* Thursday, May 25, 2017 6:25 AM
> *To:* gdd-gnso-ppsai-impl at icann.org
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review,
> Meeting Next Week Canceled to Provide Additional Review Time
>
> Thanks, Eric!
>
> I will add these to the list of topics to discuss on Tuesday. Where
> questions are re-ordered/combined from the registrar accreditation
> application, we were attempting to reduce the number of questions in
> this draft application where questions seemed like they could be
> answered together. But if the group finds that confusing, we don’t
> have to take that approach.
>
> This is exactly the kind of feedback we are seeking here, so I hope
> others on the IRT have the opportunity to think about these documents
> this week.
>
> Best,
>
> Amy
>
> *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 *Eric
> Rokobauer
> *Sent:* Thursday, May 25, 2017 2:00 AM
> *To:* gdd-gnso-ppsai-impl at icann.org <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review,
> Meeting Next Week Canceled to Provide Additional Review Time
>
> Thank you Amy for providing the documentation for review. Please find
> some remarks and thoughts on the questions presented.
>
> /Referencing the comparison document that shows the differences
> between the current ICANN application for registrar accreditation and
> the draft v1 application for privacy/proxy service provider
> accreditation./
>
> * Why is some of the draft P/P application reorganized from what is
> used for registrars? For instance, line 2 has legal for form of
> applicant for registrars, but that seems to be missing for P/P
> providers. Not sure of the reason for these differences.
> * A.1 for the P/P draft has a note stating "combination of Rr APP Qs
> 1 and 4". What was the reasoning there?
> * Regarding line 5 - do we not intend to ask for documentation of
> good standing for P/P providers the way we do for registrars? Was
> it not the PPSAI PDP WG intention to hold the P/P providers to the
> same accreditation standards as registrars?
> * Leading into comments below, might work to start off the
> application with “Are you affiliated with an ICANN-accredited
> registrar?” for clarity and to help streamline.
>
> /Referencing the annotated version of the draft v1 application for
> privacy/proxy service provider accreditation./
>
> * 12 months makes sense for a timeline. I remember one comment came
> up during our last call inquiring if ICANN would take applications
> before month 3 when application window starts. Any update there?
> * Is there interest in reducing the application window itself
> (between month 3 and 6)? Less time to apply, but quicker
> turnaround for all? Interested for thoughts here from IRT.
>
> /As you are reviewing these documents, please consider the following
> questions:/
>
> /(a)////Is this proposed process consistent with the intent of the
> Policy recommendations?/
>
> Yes, but the misalignment of requirements (line by line) between the
> current registrar application and the p/p draft makes this difficult
> to compare the two. Can we realign or display in a different manner?
>
> /(c)////Are there areas where ICANN should consider streamlining the
> evaluation for registrar-Affiliated providers?/
>
> This was something I had called out in our last call. Certain
> questions specifically associated to registrar operations (data
> escrow, registrant validation/verification) should be sectioned
> together. If applicant states to be affiliated with a registrar,
> ICANN will be able to quickly take that said group of answers and
> cross check with what should already be available from the
> accredited registrar provided.
>
> /(d)////Are there processes/criteria that may require “implementation
> adjustment” (as noted in p. 6 of the Final Report) in the case of
> providers that are not affiliated with ICANN-accredited registrars?/
>
> Yes. Unaffiliated P/P providers need to complete the full application
> with all requirements for operation answered.
>
> /(e)////Should ICANN consider reducing the number of evaluation
> questions and instead ensure that the applicant understands and agrees
> to comply with the relevant requirements via the required applicant
> educational program (and screening test, as discussed in April?). If
> so, which questions do you believe could/should be evaluated in this
> manner?/
>
> Yes. Primarily those that looked to have been designed for registrar
> operations. Details that P/P provider applicants may not necessarily
> be privy to.
>
> * D.2 - Length of time already providing service. How does that
> impact approval if applicant properly answers requirements asked
> for elsewhere in the application?
> * D.4 - Registration volume. How would that impact the approval of
> the accreditation?
> * D.6/D.7 - Both seem to ask the same thing? Consolidate or refine?
> * D.8 - Staffing - Maybe something that can be grouped near
> registrar operations questions. If applicant is affiliated with a
> registrar, I do not think it will be easy to call out how much
> staff specifically will be involved with this part of operations.
>
> Regards,
>
> Eric
>
> On Wed, May 24, 2017 at 1:43 PM, Metalitz, Steven <met at msk.com
> <mailto:met at msk.com>> wrote:
>
> Thanks for preparing these additional documents, Amy.
>
> One fairly small point: the draft P/P accreditation application
> omits questions regarding proof of the applicant’s standing to do
> business in the jurisdiction in which it claims to be domiciled.
> By comparison, question 3 and 5 of the registrar application ask
> for this information. I note that the P/P application asks for a
> “business registration certificate” as a “required appendix” –so
> maybe #3 is covered (though perhaps it should be clarified just
> what the applicant is required to submit, i.e., a current
> certificate issued by the jurisdiction in which domicile is
> claimed). But is there a reason applicant would not be required
> to show that what it asserts to be its form of business
> organization is in fact reflected in “documentation demonstrating
> that the Applicant entity is legally established and in good
> standing”, to quote Q.5 of the registrar application? Because in
> some circumstances the provider could designate the jurisdiction
> in which it is organized as the venue for resolving disputes,
> wouldn't it be important to document that it is in fact organized
> there, that it is subject to service of process there, and that it
> is in good standing in the eyes of the courts or other relevant
> authorities?
>
> I may have other questions to raise as I continue to go through
> these documents but thought I would not wait to accumulate them,
> in order to meet your requested deadline.
>
> *image001*
>
> *Steven J. Metalitz *|***Partner, through his professional
> corporation*
>
> T: 202.355.7902 <tel:%28202%29%20355-7902> | met at msk.com
> <mailto:met at msk.com>
>
> *Mitchell Silberberg & Knupp**LLP*|*www.msk.com <http://www.msk.com/>*
>
> 1818 N Street NW, 8th Floor, Washington, DC 20036
>
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>
> *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
> <mailto:gdd-gnso-ppsai-impl-bounces at icann.org>] *On Behalf Of *Amy
> Bivins
> *Sent:* Tuesday, May 23, 2017 12:13 PM
> *To:* gdd-gnso-ppsai-impl at icann.org
> <mailto:gdd-gnso-ppsai-impl at icann.org>
> *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review,
> Meeting Next Week Canceled to Provide Additional Review Time
>
> Dear Colleagues,
>
> This is a reminder that we are seeking your feedback on the
> documents referenced below no later than Thursday 25 May. Your
> feedback on these will likely be the bulk of our agenda for next week.
>
> Best,
> Amy
>
> Sent from my iPhone
>
> > On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins at icann.org
> <mailto:amy.bivins at icann.org>> wrote:
> >
> > Dear Colleagues,
> >
> > Thanks so much for your active participation on yesterday’s
> Privacy/Proxy IRT call. The meeting recording and materials are
> available on the wiki:
> https://community.icann.org/display/IRT/16+May+2017
> >
> > As a reminder, we are requesting your feedback on the draft v1
> applicant guide, distributed to the IRT last week and also
> attached. Following our discussion yesterday, I created two new
> documents to aid your review of the draft applicant guide:
> >
> > (1) a comparison document that shows the differences between the
> current ICANN application for registrar accreditation and the
> draft v1 application for privacy/proxy service provider
> accreditation (attached).
> >
> > (2) An annotated version of the draft v1 application for
> privacy/proxy service provider accreditation (attached), noting
> questions that are proposed in response to a specific
> recommendation from the Final Report.
> >
> >
> > As you are reviewing these documents, please consider the
> following questions:
> >
> > (a) Is this proposed process consistent with the intent of the
> Policy recommendations?
> >
> > (b) Do the proposed evaluation criteria seem to be consistent
> with the intent of the Policy recommendations?
> >
> > (c) Are there areas where ICANN should consider streamlining the
> evaluation for registrar-Affiliated providers?
> >
> > (d) Are there processes/criteria that may require
> “implementation adjustment” (as noted in p. 6 of the Final Report)
> in the case of providers that are not affiliated with
> ICANN-accredited registrars?
> >
> > (e) Should ICANN consider reducing the number of evaluation
> questions and instead ensure that the applicant understands and
> agrees to comply with the relevant requirements via the required
> applicant educational program (and screening test, as discussed in
> April?). If so, which questions do you believe could/should be
> evaluated in this manner?
> >
> >
> >
> > Next week’s meeting, scheduled for 23 May, is canceled to
> provide additional time for this review. Our next meeting will be
> on 30 May 2017. Please send your feedback on these documents to
> the list no later than your EOD 25 May.
> >
> >
> >
> > If you have questions or comments between now and then, please
> don’t hesitate to reply to the list or contact me directly.
> >
> >
> >
> > 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 <tel:%28202%29%20249-7551>
> > Fax: +1 (202) 789-0104 <tel:%28202%29%20789-0104>
> > Email: amy.bivins at icann.org<mailto:amy.bivins at icann.org
> <mailto:amy.bivins at icann.org%3cmailto:amy.bivins at icann.org>>
> > www.icann.org <http://www.icann.org><http://www.icann.org>
> >
> >
> >
> > <PP_App_Guide_IRTv1.pdf>
> > <Rr_PP_App_Comparison.pdf>
> > <PP_App_Draftv1_Annotated.pdf>
> > _______________________________________________
> > Gdd-gnso-ppsai-impl mailing list
> > Gdd-gnso-ppsai-impl at icann.org <mailto:Gdd-gnso-ppsai-impl at icann.org>
> > https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
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>
>
> --
>
> */Eric Rokobauer/*
>
> Senior Manager, Registrar Compliance
>
> +1-602-226-2372 <tel:602-226-2372>
>
> *
> *
>
>
>
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