[Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Amy Bivins
amy.bivins at icann.org
Mon Aug 6 18:47:37 UTC 2018
Hi Sara and Volker (and all),
I believe the summary of where we are proceeding based on your feedback was misunderstood--we are looking at a bulk transition to a new provider, as you recommend here, in cases where the registrar will cooperate and wishes to contract with a new PP provider. We are not talking about an inter-registrar bulk transfer. I think this will be more clear once the group is able to review proposed revisions to the document.
Best,
Amy
-----Original Message-----
From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Sara Bockey
Sent: Monday, August 6, 2018 2:44 PM
To: gdd-gnso-ppsai-impl at icann.org
Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Agree with Volker. I don't think using the word "transition" helps and the idea that changing PP Provider requires a change of registrar is just wrong. The Provider is a separate entity from the registrar. Registrars need the ability to contract with a new PP Provider should a Provider's service be terminated.
Sara Bockey
GoDaddy | Senior Policy Manager
+1 480-366-3616
sbockey at godaddy.com
This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.
On 8/6/18, 3:54 AM, "Gdd-gnso-ppsai-impl on behalf of Volker Greimann" <gdd-gnso-ppsai-impl-bounces at icann.org on behalf of vgreimann at key-systems.net> wrote:
Hi Amy,
transition is just as bad. There simply is no reason why a termination
of a privacy service provider would necessitate or even justify a
registrar transfer. Requiring registrar coordination does not help
either. The registrant expects to find the domain names he owns in the
user account with the provider he chose, not with another registrar he
has no agreement with, has not provided payment details to. etc.
You are creating a nightmare for registrars and registrants alike, with
no justification from anything the WG decided.
Oh, and the fees need to go!
Best,
Volker
Am 06.08.2018 um 09:53 schrieb gtheo:
> Hi Amy,
>
> Correct me if I am wrong, but does that imply the proposed fees are
> based on the onboarding, but there are no details regarding the
> operational costs?
>
> Thanks,
>
> Theo
>
>
> Amy Bivins schreef op 2018-08-03 07:34 PM:
>> Thanks, Sara and Theo for your feedback on this.
>>
>> I'm working on some proposed edits to this document based on your
>> feedback--once I can discuss with Legal I'll have an updated draft for
>> you. I hope to be able to send a draft to the list next week.
>>
>> To start, we're planning to change the word "transfer" to "transition"
>> and to explicitly require coordination with the registrar as a
>> necessary step for a bulk transition. We're also taking another look
>> at notice requirements where a registrar is not involved in the
>> facilitation of a bulk transfer, in which case a customer might need
>> to transfer out if the customer wishes to transition to a new PP
>> service provider.
>>
>> Theo, regarding your comments on the fees proposal, the activities
>> listed as contributors to ongoing expected program costs (one of the 3
>> elements that fed into the proposed fees determination) were not
>> itemized the way they were for the application phase (this would
>> require a broader analysis).
>>
>> Thanks, all, and have a great weekend.
>>
>> Amy
>>
>>
>>
>> -----Original Message-----
>> From: Gdd-gnso-ppsai-impl
>> [mailto:gdd-gnso-ppsai-impl-bounces at icann.org] On Behalf Of Sara
>> Bockey
>> Sent: Tuesday, July 31, 2018 8:31 AM
>> To: gdd-gnso-ppsai-impl at icann.org
>> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP
>> De-Accreditation Procedure Document Attached for IRT review
>>
>> Again. Agree with Theo. Use of the word “transfer” is confusing and
>> problematic. We need to be able to reassign the service, contract
>> with a new provider. Actual transfers would seem to be a dead last
>> option. We don’t want to penalize the customer just because the P/P
>> service changes.
>>
>> Sara
>>
>> Sent from my iPhone. Apologies for typos and/or brevity.
>>
>>> On Jul 31, 2018, at 1:39 AM, gtheo <gtheo at xs4all.nl> wrote:
>>>
>>> I think the word transfer is somewhat confusing or does not meet the
>>> objective or can cause results that are not wanted.
>>>
>>> I can imagine a reseller using privacy provider X.
>>> Privacy Provider X merges or hands over the business to Privacy
>>> Provider ABC.
>>>
>>> The most logical path is that the reseller updates the domain names
>>> to the details of Privacy Provider ABC.
>>>
>>> Transfering the domain names in bulk or through an inter-registrar
>>> transfer to the registrar of privacy provider ABC could be not
>>> wanted for various reasons.
>>> Reseller has to implement a new API with the new registrar.
>>> Billing issues.
>>> The new registrar may lack features key critical to the reseller at
>>> the current registrar.
>>> Etc the list is long.
>>>
>>> A bulk transfer at a registry level, poorly communicated could
>>> create chaos.
>>>
>>> Regarding the fees. The fee document seems to have two major
>>> components.
>>> Program Startup and Application Processing Here are all the costs
>>> listed.
>>>
>>> Then there is the; Ongoing Accreditation Program Maintenance Here are
>>> no fees listed.
>>> Are the fees of the ongoing program maintenance listed in the
>>> program startup and application processing?
>>>
>>> For example, Complaint processing is listed as ongoing. What are
>>> those costs? Or can I simply exclude them as those costs are not
>>> taken into account? How does that work?
>>> I think it is relevant as I expect complaint processing cannot be
>>> compared to the current situation in case of a registrar.
>>>
>>> Thanks!
>>> Theo
>>>
>>>
>>> Sara Bockey schreef op 2018-07-30 10:31 PM:
>>>> Apologies for weighing in late here, but I agree with Theo. I'm not
>>>> understanding why the registrar would need to change per se. I also
>>>> can imagine a scenario where a privacy provider (or registrar)
>>>> reaches an agreement with another privacy provider to provide
>>>> privacy. In fact, I think this would be the most likely option we
>>>> would want - allow the registrar to contract with a new provider.
>>>> Sara
>>>> sara bockey
>>>> sr. policy manager | GoDaddy™
>>>> sbockey at godaddy.com 480-366-3616
>>>> skype: sbockey
>>>> This email message and any attachments hereto is intended for use
>>>> only by the addressee(s) named herein and may contain confidential
>>>> information. If you have received this email in error, please
>>>> immediately notify the sender and permanently delete the original and
>>>> any copy of this message and its attachments.
>>>> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts"
>>>> <gdd-gnso-ppsai-impl-bounces at icann.org on behalf of gtheo at xs4all.nl>
>>>> wrote:
>>>> Hi Amy,
>>>> If it is supposed to address both situations, isn't it somewhat
>>>> odd a
>>>> privacy provider can order a bulk transfer to another privacy
>>>> provider
>>>> at another registrar?
>>>> I can imagine a scenario where a privacy provider reaches an
>>>> agreement
>>>> with another privacy provider to update all the domain names to one
>>>> privacy provider. But to transfer domain names in bulk in the above
>>>> scenario, does that benefit the registrant? I think it could create
>>>> total chaos and disruption of services. Or is the above scenario
>>>> unthinkable and am I chasing ghosts here?
>>>> Thanks,
>>>> Theo
>>>> On 26-7-2018 15:03, Amy Bivins wrote:
>>>> > Hi Theo,
>>>> >
>>>> > Thanks for your feedback.
>>>> >
>>>> > This was drafted to try to accommodate both types of situations,
>>>> though, practically speaking, it seems probable that in most cases
>>>> this would often involve an inter-registrar transfer.
>>>> >
>>>> > There's nothing explicit in the document that would require
>>>> obtaining consent from the registrar to a provider-provider bulk
>>>> transfer under the same registrar. Do you (and others) think this
>>>> should be an explicit requirement?
>>>> >
>>>> > Best,
>>>> > Amy
>>>> >
>>>> > -----Original Message-----
>>>> > From: gtheo [mailto:gtheo at xs4all.nl]
>>>> > Sent: Thursday, July 26, 2018 4:54 AM
>>>> > To: gdd-gnso-ppsai-impl at icann.org
>>>> > Cc: Amy Bivins <amy.bivins at icann.org>
>>>> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP
>>>> De-Accreditation Procedure Document Attached for IRT review
>>>> >
>>>> > Hi Any, et al,
>>>> >
>>>> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from
>>>> one privacy provider to another, or can a privacy provider request a
>>>> transfer of all the domain names that are being used by a privacy
>>>> provider at a registrar to another privacy provider at another
>>>> registrar?
>>>> > I am somewhat struggling here with what we want to achieve and
>>>> what a privacy provider can do here.
>>>> >
>>>> > I think in all cases when a privacy provider requests a bulk
>>>> transfer the sponsoring registrar has to agree also?
>>>> >
>>>> > Thanks,
>>>> >
>>>> > Theo
>>>> >
>>>> >
>>>> >
>>>> > Amy Bivins schreef op 2018-07-25 03:37 PM:
>>>> >> Dear Colleagues,
>>>> >>
>>>> >> Attached you will find a new draft of the PP De-accreditation
>>>> and
>>>> >> transition procedure, updated based on IRT feedback and our
>>>> final
>>>> >> (prior to public comment) internal review. If you have any
>>>> further
>>>> >> questions or comments on this document, please send them to
>>>> the list.
>>>> >>
>>>> >> We're nearly finished with the final editing/review process
>>>> for the
>>>> >> applicant guide and fees document, as well (there will be
>>>> copy edits
>>>> >> but no significant substantive changes). I'll send those to
>>>> the list
>>>> >> as soon as they are complete, likely before the end of this
>>>> week.
>>>> >>
>>>> >> 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
>>>> >>
>>>> >> Fax: +1 (202) 789-0104
>>>> >>
>>>> >> Email: amy.bivins at icann.org
>>>> >>
>>>> >> www.icann.org [1]
>>>> >>
>>>> >>
>>>> >>
>>>> >> Links:
>>>> >> ------
>>>> >> [1]
>>>> >>
>>>> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
>>>> >>
>>>> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
>>>> >>
>>>> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
>>>> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e=
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