[GNSO-Accuracy-ST] Identity Proofing Clarity - Follow Up Homework

[Volker Greimann]

Hi Michael,

all such investigations are based on a substantiated whois inaccuracy
complaint where the complainant states that the registrant has provided
false details. As this regards a potential violation of our registration
agreement with the registrant we will investigate the identity of the
registrant in this specific case only. The usual complaint is from the
party listed in the registration record that they did not register the
domain name in the first place or sold it a while ago and now found that
the record was never updated by the old registrant.

That said, aside from the investigation following a substantiated
inaccuracy complaint, identity of the registrant is not required under
current policies. These cases are rather rare and are usually detected when
the listed registrant contact receives their annual WDRP mail. In these
cases we contact our customer and ask that they reach out to the registrant
with the request to update the registration details.

Sincerely,
-- 
Volker A. Greimann
General Counsel and Policy Manager
*KEY-SYSTEMS GMBH*

T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
W: www.key-systems.net

Key-Systems GmbH is a company registered at the local court of
Saarbruecken, Germany with the registration no. HR B 18835
CEO: Oliver Fries and Robert Birkner

Part of the CentralNic Group PLC (LON: CNIC) a company registered in
England and Wales with company number 8576358.

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On Fri, Oct 22, 2021 at 12:39 PM Michael Palage <michael at palage.com> wrote:

> Hello All,
>
>
>
> I was reviewing my notes from yesterday’s meeting as well as reviewing
> some of the previous email list exchanges between and I was hoping that my
> Registrar colleagues could provide a little clarity, especially Volker
> given his participation in the 2013 RAA negotiations.
>
>
>
> I believe what I have heard and read from my Registrar colleagues is that
> there is no “identity proofing” requirements in their contracts – accuracy
> is merely syntactical and operational. I apologizes in advance if I am
> mischaracterizing this and welcome any corrections. However, in Assignment
> #1, the follow excerpt from ICANN Organization Enforcement of Registration
> Data Accuracy Obligations Before and After GDPR states:
>
>
>
> [I]f 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 concerning their findings and the results of their
> investigation specific to the facts of the complaint.
>
>
>
> So it appears based on this excerpt that ICANN Contractual Compliance does
> reserve some right to inquiry about the “identity” of the Registrant.
> Therefore, I believe potential clarifying questions to ICANN Org could
> might include: does ICANN Compliance believe that it has the ability to
> inquiry about the “identity” of a registrant? If so, what is the
> contractual basis of this authority. Finally, what are the numbers
> associated with these types of inquiries, e.g. percentage of overall
> accuracy complaints and raw numbers.
>
>
>
> Thoughts? Comments?
>
>
>
> Best regards,
>
>
>
> Michael
>
>
>
>
>
>
>
>
>
>
>
>
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