[Gdd-gnso-ppsai-impl] Materials, action items from 3 October Privacy/Proxy IRT call

[DiBiase, Gregory]

Hi Caitlin,

Some initial comments on the revised Applicant Guide:


1.       The two track system is a big improvement.  Much clearer.

2.       I noticed the fees have been removed.  Will new fees be proposed for next week’s meeting?  I also believe ICANN was going to provide actual costs for background checks (the rationale for application fees), when will those be provided?

3.       Re Section 3.2, why is the applicant providing information on when ICANN last performed a background check on the applicant’s affiliated entity?  Doesn’t ICANN know this?  I would like to reiterate Volker’s position that background checks should not be required for affiliated entities.  If a check has already been conducted on an affiliated entity, responses to the questions in the rest of section 3 should be sufficient.

4.       Re 5.2: I lost track of where we are on identifying that the registration is a privacy/proxy registration, but wasn’t this concern already accounted for in the rules generally?  I don’t think it should solved by providers individually and therefore this question is not necessary.

5.       Generally, the change from asking for descriptions to asking for confirmation is welcome.

From: gdd-gnso-ppsai-impl-bounces at icann.org [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Caitlin Tubergen
Sent: Wednesday, October 04, 2017 6:36 PM
To: gdd-gnso-ppsai-impl at icann.org
Subject: [Gdd-gnso-ppsai-impl] Materials, action items from 3 October Privacy/Proxy IRT call

Dear Colleagues,

Thank you for your participation on the last Privacy/Proxy IRT call on Tuesday, 3 October. For those who could not attend, I encourage you to review the recording (https://participate.icann.org/p8dnkiub56v/<https://participate.icann.org/p8dnkiub56v/?OWASP_CSRFTOKEN=ebda0b0ecee56f6650584ca3c6df298c9b9b9d14eecf0b0d980f2dd84f7c45cb>) and materials on the wiki, https://community.icann.org/display/IRT/03+October+2017.

I attached two documents for your review:
(1)    The updated Applicant Guidebook/Application (v3)
(2)    The updated De-Accreditation Procedure (v2)

Notes on Updated Applicant Guide

We received feedback from the IRT that the application process should be simplified, which included (1) consolidation of “tracks”, i.e., rather than four tracks, there should be two tracks: unaffiliated entities and affiliated entities; (2) a streamlined application, which includes only necessary long-form/essay questions and a “check box”, short form for the majority of questions.  Further to that feedback, please review the next iteration (v3) of the Applicant Guidebook, with particular attention to Sections 5-6 (p. 10-11).  Please provide any additional feedback to the list by Tuesday, 10 October.  We will discuss any updates on our call next Tuesday.

Notes on De-Accreditation Procedure

Further to your feedback on the last call about de-accreditation, we removed the text in section 2.4.6 about a customer’s personal information being revealed in WHOIS following a termination of a P/P Provider to reflect the reality of a termination, which would involve a potential suspension (per the Whois Accuracy Program Specification (WAPS) as opposed to publication of underlying customer information in RDDS.  A few members of the IRT expressed concern with treating the information as inaccurate and suspending names after 15 days, per the WAPS.  We proposed to change that period to 30 days, i.e., following a termination of a P/P provider, the gaining provider/registrar would have 30 days to contact the customers to correct the inaccurate WHOIS information before potential suspension.

Additionally, a member of the IRT expressed a concern as to which entity (the terminated or gaining provider) would be in charge of processing abuse complaints during terminations. Until the date of P/P provider is terminated, the terminating provider would be responsible for handling abuse tickets, as that entity would still be under contract.  Following the termination date, the new provider would be responsible for processing abuse complaints.  A member of the IRT noted a potential gap, where an individual/entity may file a complaint with the terminating entity, but if it is not responded to, it would need to file a new version of the same complaint with the gaining entity.  If you have any suggestions about how this should be handled, please feel free to make suggestions to the list by Tuesday, 10 October.

On our next call on Tuesday, 10 October, we will be discussing the proposed updates to the attached documents.  I am also hoping to have the next iteration of the Accreditaiton Agreement to share with you early next week.

Thank you again for all of your work on this!

Best regards,

Caitlin



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