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

Volker Greimann volker.greimann at centralnic.com
Fri Apr 22 13:22:09 UTC 2022


sadly this is not at al helpful for our work l as it only describes
potential methods of verification without addressing one the perceived need
for it and I wonder what your purpose is for sharing this distraction from
our task.

I think this is outside the scope of us as a scoping team at this time,
even though it may be helpful for a PDP down the road. Our job is not to
propose possible verification methods but to see whether there is a sizable
issue with registration data accuracy in the first place and whether that
issue that needs policy work or whether the processes and policies
currently in place already serve the intended purpose.

The slide deck does however showcase the issues that ICANN and the RRSG
have repeatedly outlined when looking at the feasibility of certain
verifications as it shows how limited the scope of the various methods
employed by EURID is even when only looking at European registrants. Try to
expand it to a global pool of registrants and you may be able to imagine
what issues this entails.

Volker A. Greimann
General Counsel and Policy Manager

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On Fri, Apr 22, 2022 at 1:39 PM Michael Palage <michael at palage.com> wrote:

> 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,
> Michael
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