[Gdd-gnso-ppsai-impl] Materials, Agenda for 5 Sept PP IRT Meeting

Mon Sep 4 19:36:56 UTC 2017

Agreed, if the provider is awol, then we should not expect much from them.

Section 3.3.5 Without going into the operational challenges we 
might/should make sure this section allows Registrars a lot of 
flexibility here. I cautioned about the GDPR data breach possibility, 
most likely ICANN as the data controller will be liable here, but we 
should come up with something that makes sure this does not happen. This 
might be a sub team task.

3.5 A privacy service is a service, not a domain name. Under the current 
language, a customer can choose between privacy providers without 
transferring the actual domain name. The same logic applies when it 
comes to de-accreditation.

Section 5.
I am not going to belabor this point.
This procedure deals with domain names, where a Registrar gets domain 
names transferred to its accreditation.
What is happening is that a domain name registrant contact gets 
updated.  An update to the WHOIS records at best.

5.4  Good to notice that ICANN will do all the work here.
To make this work detailed Escrow data for nonaffiliated providers is 
key here.

De-Accredited Registrar Transition Procedure in general.
Tom Barret pointed out that this is in some cases, call it doing the 
community a favor here. You might get 1000 domain names on your 
accreditation really easy if you get some renewals out of it, great, you 
made some money as a Registrar, though most likely you did a ton of work 
and got paid peanuts in the end. But that is a business decision or 
better put, you doing ICANN a favor and its community and the registrants.

What I the privacy provider is offering the privacy service for free? As 
the gaining privacy provider and you charge money you know for sure that 
those customers are not going to renew, they want out to another privacy 
provider that offers the service for free.
If if the gaining privacy provider does provide the service for free 
then this provider will do a ton of work for nothing, there is nothing 
to gain except liability issues.
In fact, you have to verify, suspend domain names and your support staff 
will go nuclear and not having a good week.

6
I expect there will be no pool of privacy providers. I have looked at 
the DART program a few years back; I truly appreciate what Tom Barret 
and other Registrars in that pool are doing.
But the reality it is an amazing boatload of work. Sometimes the data 
quality is poor and requires a lot of scripting.

Best regards,

Theo Geurts

On 4-9-2017 12:57, Michele Neylon - Blacknight wrote:
>
> Amy et al
>
> Just browsing this quickly and I can see some serious gaps
>
> If ICANN is suspending a provider it’s due to any number of issues so 
> relying on the same provider you’re suspending to send notices to 
> anyone is simply not going to work.
>
> You’re probably suspending them for breaching the policies / contract 
> etc., so I can’t imagine they’d be likely to start sending out notices 
> at this juncture.
>
> All of the language around customer notification is linked to the 
> provider co-operating and acting and to be frank I can’t see that 
> happening in a lot of cases.
>
> Regards
>
> Michele
>
> --
>
> Mr Michele Neylon
>
> Blacknight Solutions
>
> Hosting, Colocation & Domains
>
> https://www.blacknight.com/
>
> http://blacknight.blog/
>
> Intl. +353 (0) 59  9183072
>
> Direct Dial: +353 (0)59 9183090
>
> Personal blog: https://michele.blog/
>
> Some thoughts: https://ceo.hosting/
>
> -------------------------------
>
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business 
> Park,Sleaty
>
> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>
> *From: *<gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Amy 
> Bivins <amy.bivins at icann.org>
> *Reply-To: *"gdd-gnso-ppsai-impl at icann.org" 
> <gdd-gnso-ppsai-impl at icann.org>
> *Date: *Friday 1 September 2017 at 15:46
> *To: *"gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
> *Subject: *[Gdd-gnso-ppsai-impl] Materials, Agenda for 5 Sept PP IRT 
> Meeting
>
> Hello, All,
>
> Attached is the first IRT discussion draft of the privacy/proxy 
> provider suspension and de-accreditation procedure, which we will be 
> discussing during Tuesday’s IRT meeting. Please review this document 
> prior to our meeting on Tuesday.
>
> In addition, we plan to discuss the issue raised on-list by Sara 
> Bockey, regarding the draft PPAA’s requirement for 24/7/365 monitoring 
> of a provider’s abuse contact (modeled on the RAA). We are also 
> planning to discuss next steps on data retention.
>
> As a reminder, please send any additional feedback you have regarding 
> the issues discussed during Tuesday’s meeting to the list this week.
>
> Thanks, and have a great weekend.
>
> 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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