[Gnso-ppsai-pdp-wg] For your review - updated template Cat B - question 2

Mon Mar 17 21:44:50 UTC 2014

Val, please note that the draft preliminary recommendation proposes that
'Similar to ICANN¹s Whois Data Reminder Policy
(http://www.icann.org/en/resources/registrars/consensus-policies/wdrp), the
P/P provider should be required to inform the P/P customer annually of
his/her requirement to provide accurate and up to date contact information
to the P/P provider. If the P/P provider has any information suggesting that
the P/P customer information is incorrect (such as P/P service receiving a
bounced email notification or non-delivery notification message in
connection with compliance with data reminder notices or otherwise) for any
P/P customer, the P/P provider must verify or re-verify, as applicable, the
email address(es). If, within fifteen (15) calendar days after receiving any
such information, P/P service does not receive an affirmative response from
the P/P customer providing the required verification, the P/P service shall
verify the applicable contact information manually'.

Does that address your last point? If not, do you or any of the others that
have indicated that they agree with Todd's assessment have any suggestions
for additions / changes to the draft preliminary recommendation that the WG
could review and consider during its meeting tomorrow?

Best regards,

Marika

From:  Valeriya Sherman <VSherman at sgbdc.com>
Date:  Monday 17 March 2014 21:08
To:  "Metalitz, Steven" <met at msk.com>, "'Williams, Todd'"
<Todd.Williams at turner.com>, Marika Konings <marika.konings at icann.org>,
"gnso-ppsai-pdp-wg at icann.org" <gnso-ppsai-pdp-wg at icann.org>
Subject:  RE: [Gnso-ppsai-pdp-wg] For your review - updated template Cat B -
question 2

I, Jim Bikoff, David Heasley, and Griffin Barnett agree with Todd's
assessment:  

Contact information that is ultimately revealed is valuable only if it is
accurate.  

The validation/verification requirements should be consistent with the 2013
RAA requirements, but should go above and beyond those requirements to
ensure the accuracy of contact information.

Registrars already send an annual Whois Data Reminder Policy notification to
registrants, reminding them to provide accurate and up-to-date information.

Similarly, the privacy/proxy customer's contact information should be
verified upon initial registration of the domain name (either by the
registrar or the Privacy/Proxy Service Provider) and periodically thereafter
by automated annual email re-verification notifications that require an
affirmative response by the P/P customer.  Absence of a response would
trigger a follow-up, reminding the privacy/proxy customer to provide
accurate and up-to-date information.

Regards,

Valeriya Sherman
Silverberg, Goldman & Bikoff, L.L.P.
1101 30th Street, N.W.
Suite 120
Washington, D.C. 20007
Tel 202.944.2330
Cell 303.589.7477
vsherman at sgbdc.com <mailto:vsherman at law.gwu.edu>

From: gnso-ppsai-pdp-wg-bounces at icann.org
[gnso-ppsai-pdp-wg-bounces at icann.org] on behalf of Metalitz, Steven
[met at msk.com]
Sent: Monday, March 17, 2014 6:13 AM
To: 'Williams, Todd'; Marika Konings; gnso-ppsai-pdp-wg at icann.org
Subject: Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat B -
question 2

I agree with Todd¹s characterization of the status of this discussion, and
that the questions he highlights are still open.

Another aspect of the second question below is how the p/p service provider
should handle situations in which the contact information supplied by the
customer cannot be verified. In the parallel situation involving non-proxy
registrations, the RAA specification calls either for suspension of the
registration, or ³manual verification,² which is not defined. How should
this apply in the p/p service scenario?

Steve Metalitz  

From: gnso-ppsai-pdp-wg-bounces at icann.org
[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Williams, Todd
Sent: Friday, March 14, 2014 4:53 PM
To: Marika Konings; gnso-ppsai-pdp-wg at icann.org
Subject: Re: [Gnso-ppsai-pdp-wg] For your review - updated template Cat B -
question 2

Thanks Marika.  I missed part of the call on Tuesday where this may have
been discussed, but I don¹t see how the draft preliminary recommendation
follows from the attached Word document, insofar as it concludes that p/p
customer data should be validated and verified in a manner consistent with
the requirements outlined in the 2013 RAA.  I thought the current posture
was that the WG has basically agreed to the 2013 RAA requirements as a
floor, but that there was not yet agreement on: 1) whether
validation/verification requirements should go beyond the 2013 RAA; and 2)
if so, how.

On the first question (2013 RAA vs. ³more²), it appears that more of the
responses in the attached argue for ³more² than not.  That also seems to
have been an open topic in our email threads (see attached).  Just to
reiterate from that thread, the basic argument on the ³more² side (which I
agree with) is that in order to partially offset the delay that will
inevitably occur when accessing p/p data, the ³more² should consist of
whatever reasonable validation/verification steps can be taken to increase
the likelihood  that the information ultimately obtained will be accurate
enough to facilitate contact.  I suppose that if we ultimately settle on a
³reveal² procedure that is essentially instantaneous in certain cases (once
we get to discussing ³reveal² procedures), that may mitigate this concern.
But absent assurances on that point, I would think we need to address it.

On the second question: the attached appears to include multiple proposals
as to what may or may not ultimately comprise the ³more² (e.g., email and
phone vs. or; periodic/annual re-verification vs. re-verification with
information suggesting the contact information is incorrect; etc.).  Have we
debated the relative merits of those?  Are some more likely to be effective
than others?  I have my thoughts, but I¹m curious to hear what everybody
else thinks.

Thanks all.

Todd.              

From:gnso-ppsai-pdp-wg-bounces at icann.org
[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Marika Konings
Sent: Thursday, March 13, 2014 7:04 AM
To: gnso-ppsai-pdp-wg at icann.org
Subject: [Gnso-ppsai-pdp-wg] For your review - updated template Cat B -
question 2

Dear All,

Following our call earlier this week, please find attached the updated
template for Category B  question 2. To facilitate your review, I've posted
below the draft preliminary recommendation in which we've aimed to capture
the conversation to date taking into account the language of the Whois
Accuracy Specification Program of the 2013 RAA. If you are of the view that
this does not accurately capture the WG's view to date and/or have specific
suggestions for changes / edits, please share those with the mailing list.
Also, if there are any other issues that need to be addressed in relation to
this question and/or the preliminary recommendation, please share those as
well.

Best regards,

Marika

Draft Preliminary Recommendation  Category B  question 2 (Should
ICANN-accredited privacy/proxy service providers be required to conduct
periodic checks to ensure accuracy of customer contact information; and if
so, how?)

The WG recommends that proxy and privacy customer data be validated and
verified in a manner consistent with the requirements outlined in Whois
Accuracy Specification Program of the 2013 RAA. The WG furthermore agrees
that in the cases where validation and verification of the P/P customer data
was carried out by the registrar, reverification by the P/P service of the
same, identical, information should not be required.

Similar to ICANN¹s Whois Data Reminder Policy
(http://www.icann.org/en/resources/registrars/consensus-policies/wdrp), the
P/P provider should be required to inform the P/P customer annually of
his/her requirement to provide accurate and up to date contact information
to the P/P provider. If the P/P provider has any information suggesting that
the P/P customer information is incorrect (such as P/P service receiving a
bounced email notification or non-delivery notification message in
connection with compliance with data reminder notices or otherwise) for any
P/P customer, the P/P provider must verify or re-verify, as applicable, the
email address(es). If, within fifteen (15) calendar days after receiving any
such information, P/P service does not receive an affirmative response from
the P/P customer providing the required verification, the P/P service shall
verify the applicable contact information manually.

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