[Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Darcy Southwell
darcy.southwell at endurance.com
Mon Aug 6 19:37:00 UTC 2018
Thanks for the follow up, Amy. The PPSAI PDP was clear that P/P customers
should be notified in advance of de-accreditation. I don't see where the
PDP proposed a bulk "transition" option. Can you shed further light on the
policy recommendation since I'm not finding it?
>From an operational perspective, inserting a bulk "transition" piece really
over complicates this. Registrars of record have to collaborate with or
implement a P/P service (whether the registrar operates it or the registrar
contracts with a third party). Just like any other service a registrar
offers to a registrant in conjunction with domain name registration (e.g.,
hosting or email), the registrar will handle the decision of what to offer,
how, etc. Inserting ICANN into managing the so-called "transition" isn't
necessary.
Thanks,
Darcy
On Mon, Aug 6, 2018 at 11:51 AM Amy Bivins <amy.bivins at icann.org> wrote:
> Apologies, I should have finished that thought before hitting send.
>
> The reference to an inter-registrar bulk transfer would be in the
> circumstance where a PP provider is terminated, and the registrar elects
> not to contract with any new PP provider (so that a customer could not use
> a PP provider at that registrar at all). In that instance, the draft
> procedure would require a notice to the customer alerting the customer that
> they would have the option to initiate an inter-registrar transfer if they
> do not wish to continue to have their name with a registrar where PP is not
> an option. I hope this makes sense. I hope to have this document ready for
> the group to review this week.
>
> Best,
> Amy
>
> -----Original Message-----
> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces at icann.org]
> On Behalf Of Amy Bivins
> Sent: Monday, August 6, 2018 2:48 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
>
> 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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