[GNSO-Accuracy-ST] SSAC inputs on assignment #1
Steve Crocker
steve at shinkuro.com
Wed Dec 1 15:24:02 UTC 2021
I've added the questions shown below. In the google doc, they're numbered
16-18. Copying them into this email renumbered them 1-3.
My purpose in this note is to flag a couple of points related to points
that have come up in earlier discussion.
The first question emphasizes there are many different data elements, each
of which may -- and most likely will -- have its own validation level.
Moreover, for purposes of this question, the V2 level, operational
validation, is understood to be the same as agreed upon contractual clause
that's currently under discussion.
The second question addresses the point that some registrars and registries
may impose higher levels of validation than is required under the RA and
RAA.
The third question asks for clarification as to whether the
validation level is disclosed to the requester whenever the data element is
provided in a response. Among other things, this question speaks to Alan's
concern that a registrar might do operational validation of, say, the phone
number but not the email address, but then provide the email address and
not the phone number in response to a request.
Thanks,
Steve
1.
What are the accuracy requirements for *each* of the data elements
collected by the registrar? If possible, use the four level scale of V0,
V1, V2, V3.
V0 = No validation required.
V1 = Syntactic validation
V2 = Operational validation
V3 = Identity validation
The expected answer is
V2 for phone and/or email
V1 for country code
V0 for all other data elements
1.
Are registries and/or registrars permitted to perform or impose a higher
level of validation?
The expected answer is yes, but the documentation is not explicit.
1.
Are registrars required to provide the validation level along with the
data element in their responses, either as part of the response or in their
documentation?
The expected answer is no, but the answer should be yes.
On Wed, Dec 1, 2021 at 10:06 AM Roger D Carney via GNSO-Accuracy-ST <
gnso-accuracy-st at icann.org> wrote:
> Good Morning,
>
> Thanks Melina. In regards to the text that you highlighted, for clarity,
> my statement was point in time (Oct 21 and Oct 26), not since.
>
>
> Thanks
> Roger
>
>
> ------------------------------
> *From:* STROUNGI Melina <Melina.STROUNGI at ec.europa.eu>
> *Sent:* Wednesday, December 1, 2021 8:42 AM
> *To:* Roger D Carney <rcarney at godaddy.com>; gnso-accuracy-st at icann.org <
> gnso-accuracy-st at icann.org>
> *Subject:* RE: [GNSO-Accuracy-ST] Update - Working Accuracy Contractual
> Construct/ Definition
>
> You don't often get email from melina.stroungi at ec.europa.eu. Learn why
> this is important <http://aka.ms/LearnAboutSenderIdentification>
> Caution: This email is from an external sender. Please do not click links
> or open attachments unless you recognize the sender and know the content is
> safe. Forward suspicious emails to isitbad at .
>
>
>
> Dear all,
>
>
>
> Unfortunately, I was away on sick leave and have not managed to hear the
> recordings; so apologies in advance if I have missed important updates.
>
>
>
> Just a first reaction in relation to the point below (in highlight) that
> no one initially spoke in objection to the working definition; this is not
> entirely… accurate J I recall I had made certain remarks on the basis of
> Michael’s proposed wording – some orally and some inserted in the google
> doc. So I personally used Michael’s reworded construct as baseline.
>
>
>
> I am not aware if Michael’s proposed wording was entirely dismissed during
> the last discussions where I was not present, but for sure I had expressed
> my objections at the initially proposed ‘working definition/construct’ –
> for instance I had stressed we should also encompass any related purposes –
> not re-invent or amend current purposes but simply state what already
> exists.
>
>
>
> I understand there is confusion from many of us – including myself – as to
> what is the current status/starting basis, but hopefully we can all discuss
> about it in our upcoming meeting.
>
>
>
> Best regards,
>
> Melina
>
>
>
>
>
> *From:* GNSO-Accuracy-ST <gnso-accuracy-st-bounces at icann.org> *On Behalf
> Of *Roger D Carney via GNSO-Accuracy-ST
> *Sent:* Wednesday, December 1, 2021 3:13 PM
> *To:* gnso-accuracy-st at icann.org
> *Subject:* Re: [GNSO-Accuracy-ST] Update - Working Accuracy Contractual
> Construct/ Definition
>
>
>
> Good Morning,
>
>
>
> Thank you for your note Michael, but I think it may be a bit misleading
> and the RrSG does not (and did not) agree with the suggested updates to the
> current working definition of accuracy.
>
>
>
> As you have reviewed the call on Nov 4th several times, you will have
> noted that I objected to these changes around the 1 hour and 11 minute
> point. Specifically, around adding any mention of identity requirements as
> that is just not the case in our contract or policy. I believe the
> reference to ICANN's report/memo below in your email, leaves off some
> important language/context. First, this report provides information on how
> ICANN Compliance operates, it does not add requirements (that is only done
> in contracts or Policy). Second, as I have mentioned several times, the
> mention of "identity" here does not (and cannot, see first point) add any
> requirements on the CP, it only states that ICANN Compliance may ask for
> "...further information concerning their findings...", it does not ask or
> even suggest that the Registrar do anything more than what they have
> already done in their investigation.
>
>
>
> The one item I do believe we agreed to was around the "affirmative
> response" idea. I don't have the specifics on this one but I think Sarah
> brought up support on adding language around that idea.
>
>
>
> Additionally, as I (and others) have mentioned many times we did not
> provide a proposed definition we provided the current working definition. I
> understand that people may want to update/expand that definition and I
> believe that is why the GNSO Council formed this Scoping Team.
>
>
>
> I will also point to prior calls, like the Oct 21st call where this
> working definition was presented, and we had agreement from several SGs,
> staff and the Chair that this was the baseline definition that we would
> work from moving forward. I will note that I saw no chat nor anyone speak
> in objection to this working definition. I once again brought this point
> of agreement up during our ICANN session (36 min) and once again I did not
> see or hear any objections to this being the baseline. Obviously, some
> minor tweaks would occur, but the suggested changes were not minor and adds
> responsibilities that just do not exist today.
>
>
>
> To be clear the RrSG does not agree with the suggested updates to the
> working definition.
>
>
>
>
>
> Thanks
>
> Roger
>
>
>
>
> ------------------------------
>
> *From:* GNSO-Accuracy-ST <gnso-accuracy-st-bounces at icann.org> on behalf
> of Michael Palage <michael at palage.com>
> *Sent:* Tuesday, November 30, 2021 1:57 PM
> *To:* 'Lori Schulman' <lschulman at inta.org>; 'Sarah Wyld' <swyld at tucows.com>;
> gnso-accuracy-st at icann.org <gnso-accuracy-st at icann.org>
> *Subject:* Re: [GNSO-Accuracy-ST] Update - Working Accuracy Contractual
> Construct/ Definition
>
>
>
> Caution: This email is from an external sender. Please do not click links
> or open attachments unless you recognize the sender and know the content is
> safe. Forward suspicious emails to isitbad at .
>
>
>
> Hello All,
>
>
>
> As someone that watched the video recording twice allow me to recount the
> events of Nov 4th.
>
>
>
> In advance of the call there had been two “definitions” (contractual
> construction / explanations) put forth for consideration. One by the
> Registrars and the one put forward by myself.
>
>
>
> In an effort to reconcile these two definitions, I opted to mark-up the
> Registrar’s “definition”. The first change was replacing the phrase “shall
> strictly” with “is.” Specifically I cited to Background Briefing
> Assignment #1 which stated in relevant part that:
>
>
>
> However, if the *complaint is about identity* (e.g., the registrant is
> not who they say they are), Contractual Compliance may ask the registrar to
> provide further information. (emphasis added).
>
>
>
> After the group acknowledged that this excerpt from the ICANN briefing
> document showed a larger remit than just syntactical and operational
> accuracy, the “shall strictly” phrase was redlined and replaced with ‘is.”.
> Alan Greenburg from ALAC tired to propose an alternative wording but the
> redline stayed as “is”.
>
>
>
> The next proposed redline was inspired largely by the following excerpt
> from the ICANN72 GAC communique which states in relevant part:
>
>
>
> The GAC gives particular importance to the verification, validation and
> correction of all registration data by registrars, *and certain
> registries*, in line with their contractual obligations, and supports
> rigorous monitoring and enforcement of such
>
> contractual obligations by ICANN. (emphasis added)
>
>
>
> These changes again were made with no substantive opposition from the
> group.
>
>
>
> As I have stated previously these agreed upon changes where lost when the
> document was exited at the end of the call. I have consulted with ICANN Org
> and they are unaware of how these changes were lost. However, I believe the
> video clearly shows that the deletion was NOT an intentional act because no
> one spoke to the text being removed, it just disappeared. Please review
> the video for yourself, I have provided the time stamp to help make
> everyone’s review easier.
>
>
>
> Now if the RySG and RsSG are going to maintain their objection to the
> previous redline “definition” and instead advocate for the RrSG
> “definition” we will address this topic AFTER the we conclude the questions
> to ICANN Org, but before we begin our GAP analysis.
>
>
>
> I do have a specific request for Marc, Beth and Sofie. During the next
> RySG call could you seek clarification from the RySG on whether Registries
> believe they have a right under their Registry Agreement to verify the
> accuracy of data elements that they process as part of domain name
> registrations in their respective TLDs. Additionally, what steps if any
> does ICANN Compliance take in connection with Registry Audits regarding
> this verification as I do believe it is relevant to our discussion here in
> this Working Group.
>
>
>
> Listed below are a non-exhaustive list of Registry Operators that involve
> some level of accuracy /registrant vetting beyond just email and phone
> accuracy (syntactical and operational) as part of their registry operations:
>
>
>
> 1. From the original 2001 proof of concept round, .AERO was one of the
> first TLD that required the process of registrant data prior to being able
> to obtain a gTLD domain name registration. If you look at the current
> .AERO registration website you will see the following requirement:
>
>
>
> Obtain your .aero ID, prior to registration of your chosen domain name
> through a .aero authorised registrar, this unique validity process screens
> potential domain registrants thus ensuring the integrity and the
> exclusivity of the .aero domain.
>
> See https://information.aero/registration
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Finformation.aero%2Fregistration__%3B!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOB-UAlJdR%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993892481%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=bzqgllRezmIrWzGz%2BaZdiKoClFr0d53LVkdrM%2Fhusuc%3D&reserved=0>
> and https://information.aero/node/add/request-aero-id
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Finformation.aero%2Fnode%2Fadd%2Frequest-aero-id__%3B!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOB3ITCJxE%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993902474%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=2PEaEvgf7KpCcOk9IWI4FAmVzcMjYumHet5PpflaBmc%3D&reserved=0>
>
>
>
> 1. From the 2004 Sponsored round perhaps the best example was .XXX
> which made the following representations:
>
>
>
> 5.0 PREVENTING ABUSIVE REGISTRATIONS
>
>
>
> The Registry will authenticate members of the Sponsored Community, as part
> of the name registration process. As part of this process, the Registry
> will validate contact information for the Registrant, secure the
> Registrant’s affirmative consent to the Registry-Registrant Agreement, and
> issue unique Membership Credentials. The Membership Application Process
> must be completed before a domain name is permitted to resolve in the TLD.
>
> See https://www.icmregistry.com/about/policies/launch/#general_aval
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fwww.icmregistry.com%2Fabout%2Fpolicies%2Flaunch%2F*general_aval__%3BIw!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOB3TI9E9h%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993912474%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=HRGvEwyPJkzltdcM3Z5Rs%2BflZTLlQkKe8QriVsqPnJQ%3D&reserved=0>
>
>
>
> 1. fTLD submitted an approved RSEP to ICANN for the processing of
> Registrant information prior to registration. The name of this RSEP is
> Dynamic Registration Verification and is available here, see
> https://www.icann.org/en/system/files/files/rsep-2017039-bank-et-al-request-11dec17-en.pdf
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fwww.icann.org%2Fen%2Fsystem%2Ffiles%2Ffiles%2Frsep-2017039-bank-et-al-request-11dec17-en.pdf__%3B!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOB4HLTjfN%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993912474%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=X03pz69aKr4V9vus8QGSFJ5baNq09HVw2AkM8rcqvfw%3D&reserved=0>
> This webpage shows the information that fTLD collects from prospective
> registrants as part of their verification process, see
> https://www.register.bank/get-started/
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fwww.register.bank%2Fget-started%2F__%3B!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOBx2kcBfH%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993922455%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=opfKI3l0A1Cbh%2FHnFLdf8zC1Y2RQhKx27dtBg94BeEU%3D&reserved=0>
>
>
>
> 1. NABP, the Registry Operator of .PHARMACY, has also vetted
> prospective registrants as part of its registration process, see
> https://nabp.pharmacy/programs/accreditations-inspections/dotpharmacy/#apply
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__https%3A%2Fnabp.pharmacy%2Fprograms%2Faccreditations-inspections%2Fdotpharmacy%2F*apply__%3BIw!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOB2DdoXPP%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993922455%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=aZMtBH2NyWg0H64IABVIqqDk9aLm5q1Pc8zSbYI37Ug%3D&reserved=0>
>
>
>
> 1. In addition, every .BRAND Registry Operator has a requirement to
> limit registrations in that TLD to either the Brand owner or “Trademark
> Licensee” so this would be a further example of where a Registry Operator
> is processing data about a Registrant (e.g. Trademark Licensee) that may or
> may not appear in the Whois/RDDS output.
>
>
>
> 1. There are also numerous RSEPs filed by Registry Operators seeking
> “Registration Validation” which clearly go above just syntactical and
> operational validation, e.g. Chinese Real Name Verification.
>
>
>
> I hope this removes any ambiguity as to the events of Nov 4th. If,
> however, the RySG and RrSG maintain their objection we will revisit prior
> to our GAP analysis discussion as noted above.
>
>
>
> Best regards,
>
>
>
> Michael
>
>
>
>
>
> *From:* Lori Schulman <lschulman at inta.org>
> *Sent:* Tuesday, November 30, 2021 1:06 PM
> *To:* Sarah Wyld <swyld at tucows.com>; michael at palage.com;
> gnso-accuracy-st at icann.org
> *Subject:* RE: [GNSO-Accuracy-ST] Update - Working Accuracy Contractual
> Construct/ Definition
>
>
>
> Hi,
>
>
>
> The changes were definitely tracked. I was under the impression that we
> agreed to those changes. If so, then they should be reinserted as a
> compromise that we can live with for the purposes of the scoping exercise.
> Any binding definitions will be negotiated by the eventual PDP.
>
>
>
> With kind regards,
>
>
>
> Lori S. Schulman
>
> Senior Director, Internet Policy
>
> *International Trademark Association (INTA)*
>
> +1-202-704-0408, Skype: LSSchulman
>
> lschulman at inta.org, www.inta.org
> <https://nam10.safelinks.protection.outlook.com/?url=https%3A%2F%2Furldefense.com%2Fv3%2F__http%3A%2Fwww.inta.org__%3B!!DOxrgLBm!SlIPgOHk4NUnDgEMMf0nXcx1obQx41WYLv5aA_ETG0vREgw_a_nVQgvECCSTz8HOBycMdrw5%24&data=04%7C01%7Crcarney%40godaddy.com%7Ce9663d4bb92848d46f1708d9b4d8d81e%7Cd5f1622b14a345a6b069003f8dc4851f%7C0%7C0%7C637739666993932451%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=Fo%2FAqvfJvW%2BZDyJCMeLP%2BDSNM86v4D3Gao%2BmBH8S0MQ%3D&reserved=0>
>
>
>
>
>
> *From:* GNSO-Accuracy-ST <gnso-accuracy-st-bounces at icann.org> *On Behalf
> Of *Sarah Wyld
> *Sent:* Monday, November 29, 2021 3:27 PM
> *To:* michael at palage.com; gnso-accuracy-st at icann.org
> *Subject:* Re: [GNSO-Accuracy-ST] Update - Working Accuracy Contractual
> Construct/ Definition
>
>
>
> Hi team,
>
>
>
> I (of course) can’t speak for the registries or answer this question, but
> I do want to say, I’m glad the text in the screenshot was not updated. The
> definition in that section of the document should remain as we had proposed
> it back on Oct 29, and any changes should be tracked elsewhere. Maybe
> that’s why the changes were removed?
>
> See you tomorrow, thanks!
>
>
>
> Sarah
>
>
>
>
>
>
>
> --
>
> *Sarah Wyld*, CIPP/E
>
>
>
> Policy & Privacy Manager
>
> Pronouns: she/they
>
>
>
> swyld at tucows.com
>
> +1.416 535 0123 Ext. 1392
>
>
>
>
>
> *From: *Michael Palage <michael at palage.com>
> *Sent: *November 26, 2021 12:02 PM
> *To: *gnso-accuracy-st at icann.org
> *Subject: *[GNSO-Accuracy-ST] Update - Working Accuracy Contractual
> Construct/ Definition
>
>
>
> Hello All,
>
>
>
> For those colleagues that celebrated the Thanksgiving holiday yesterday, I
> hope you had an enjoyable time with your family and friends and did not eat
> too much. I would also like to thanks those team members that showed up
> for our brief Administrative Call yesterday.
>
>
>
> In preparing for the call yesterday I noted some of the new additions
> added by the RySG to the questions for ICANN staff. Thank you for these
> additions Roger. This flagged a previous issue which I had raised with our
> ICANN colleagues last weekend and it involves the current working
> contractual construct / definition.
>
>
>
> In the RySG questions they cited to the proposed RrSG accuracy
> “definition” (aka contractual construct):
>
>
>
> "Accuracy shall be strictly defined as syntactical accuracy of the
> registration data elements provided by the Registered Name Holder as well
> as the operational accuracy of either the telephone number or the email
> address."
>
>
>
> Last week when I was looking for the latest and greatest contractual
> construct/definition I noted that there was a technical glitch when
> reviewing the Zoom recording which I will summarize below.
>
>
>
> If you go to the Zoom recording from the Nov 4th call you will see that
> the red lined version of the contractual construct/definition which was
> agreed to during the call and which is reflected below.
>
>
>
>
>
> However, at the conclusion of the call as we were wrapping up the
> session, these edits were lost
>
>
>
>
>
>
>
> Therefore, I would like clarification from the RySG do they wish to cite
> the group’s current working contractual construct/definition that was
> agreed to during the Nov 4th call, or do they intend to cite to the RrSG
> pre November 4th call contractual construct/definition?
>
>
>
> I know these technical glitches, e.g. delta in Google Doc, Alan receiving
> emails, and the unavailability email archives makes things a little more
> challenging. However, I know our ICANN colleagues are working on the email
> issues, and I am sure we will be able to achieve most of our work
> asynchronously if we put our minds to it.
>
>
>
> Best regards,
>
>
>
> Michael
>
>
> _______________________________________________
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