[GNSO-Accuracy-ST] Potential Additional Data Points for the Groups Consideration

Michael Palage michael at palage.com
Fri Apr 22 11:39:16 UTC 2022

Hello All,


Thanks for another productive small team meeting yesterday.  As we move forward with drafting a report to the GNSO Council regarding our work in connection with Assignments 1 & 2, and how that may impact our future working regarding Assignments 3 & 4, I wanted to share some information that may be of interest to the members within the Group.


Attached is a slide deck that Hans Seeuws from EURid said I could share with the Accuracy Scoping Working Group regarding EURid’s work to increase the accuracy of registrant data through their KYC initiative. This deck is based upon a similar presentation that Hans gave at a recent CENTR meeting. While I fully support the work that EURid is doing in this area, I have personally advocated the use of an alternative term given than KYC implies a very heightened level of verification on par with the banking system.  I have often used KYR (Know Your Registrant).  I believe the European ccTLDs have been doing some ground breaking work in the area of developing proportionate registrant verification practices and I think there are some lessons to be learned and perhaps some best practices to be implemented from our European ccTLD colleagues.


I know there was a previous discussion regarding how the cross field validation requirements contained in the 2013 RAA have never been implemented because of perceived cost issues.  However, I think this provides an interesting data point on how some in the domain name ecosystem are engaged in some creative thinking.  


As we move forward with potential surveys to Registrars involving NON PII data, I came across this provision in the Nominet Registrar Accreditation Agreement that may be another data point for our consideration. According to the Nominet’s RRA, Paragraph E.1.4 of Schedule 1 in the RRA states that “that you [Registrar] have a process in place for data quality validation, which complies with our Data Quality Policy, and which is auditable by us [Nominet].”


Per Nominet’s Data Quality Policy, for Accredited Channel Partner Tag holders, these must be “written processes.” See https://nominet.uk/wp-content/uploads/2018/09/13094001/Data-Quality-Policy.pdf  Therefore, I think it would be highly informative to know how these written Data Quality Processes stack up against the 2013 RAA Accuracy requirements.   


Best regards,






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