[Gdd-gnso-ppsai-impl] Updated PPAA draft and related materials attached for IRT review

Wed Feb 28 19:16:04 UTC 2018

Dear Colleagues,

Attached is the updated PPAA draft, in redline and non-redline versions. I've also included a version with references to the Final report and notes to the IRT about where edits were made (or not made). The attached slide deck includes an overview of the accreditation program materials, remaining open issues, and identifies how each of the Final Recommendations are proposed to be implemented.

Please begin reviewing the updates to the PPAA draft and come prepared to discuss at our meeting on Tuesday. Also, please provide any final feedback on the LEA framework and reporting specification no later than this Friday, 2 March. We plan to update this draft with respect to feedback received on those issues next week as we prepare these materials for the public comment period.

Brief, high-level summary of the changes/questions for the IRT in this PPAA draft:

  1.  Non-substantive copy edits throughout
  2.  Labeling specification (and all references to this specification) deleted based on IRT feedback that the requirements therein appeared to be beyond scope. Labeling requirement included in PPAA body at Section 3.15.
  3.  Reporting specification (and references to this specification) added. Specification remains under IRT review (deadline for feedback 2 March). Links to PP IETF documents are not yet functional, as these are not yet published. These are expected to be published prior to the publication of the draft PPAA for public comment and links will be updated if needed when this specification is finalized based on final IRT feedback.
  4.  Definition of "Working Group" (applicable to amendment, negotiation processes-See, e.g., Section 7.4.1) updated throughout PPAA to eliminate references to any future PPSG. In its place, the WG will now be convened by the GNSO Council (See PPAA Section 1.43), as recommended by the IRT.
  5.  All references to a Provider terminating a customer's domain registration or requesting that a registrar do so in response to a breach of the terms of service or other wrongs have been deleted, per IRT input. (See, e.g. Section 3.5.3.1; See, specifically, Section 3.5.3.17 (regarding cancellations of services related to names that are subject to UDRP/URS proceedings.)
  6.  Explicit requirement that Provider publish its terms of service has been added (See Section 3.8.1). Prior draft referenced requirements for ToS contents but didn't explicitly require that ToS be published, as directed by the Final Report.
  7.  Abuse desk requirement in PPAA Section 3.12.1 edited to match language in Final Report (language about the abuse contact being "capable and authorized to investigate..." from the Final Report had been inadvertently deleted at some point in a prior draft).
  8.  Deletion of LEA-related abuse contact requirements in PPAA text (formerly section 3.12.2). All LEA-specific requirements are now included in the LEA Disclosure Framework Specification.
  9.  Reference to use of "high-volume, automated electronic processes..." in PPAA section 3.14 was moved to Intellectual Property Disclosure Framework Specification.
  10. Clarification added that a provider on suspended status may continue to provide services for existing registrations (Section 5.7.3)
  11. Several clean-up edits in Specification 1, Data Escrow Specification. ICANN is currently reviewing the inclusion of this Specification in the PPAA itself, as opposed to the RAA format which has the escrow specification separate from the accreditation agreement. As technical requirements/RFCs may be updated from time to time, there are benefits to having this outside the PPAA itself. IRT feedback is requested on this topic.
  12. Specification 2: Customer Data Accuracy Program Specification. Edit to Section 1, to clarify that obligation applies when Provider begins providing the Services for a name, as opposed to when the name is registered.
  13. Specification 4: Law Enforcement Authority Specification. This specification is currently under final IRT review (deadline for feedback 2 March). Substantive edits may be made after this review period. There is currently some disagreement among IRT members regarding high priority requests, specifically: (a) how the receipt process should or should not apply to high priority requests, (b) the time that should be allowed for a provider to action a "high priority" request. In addition, the IRT is considering defining "action" for greater clarity.
  14. Data retention specification: The data required to be retained has been reduced by the deletion of the labeling specification (see Section 1.1.6).

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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