[Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG call earlier today

[Graeme Bunton]

Not quite, Todd.

First, as we inform all of our customers about requests & complaints 
they would already know the answer by looking at their communications 
from us. Should also be the case with most providers.  That said...

My answer to 4&5 was an educated* guess, so I may have been 
over-reaching there.   If i could clarify slightly - I wouldn't be 
surprised if a provider could tell you every interaction around a 
single, specific domain, but have a difficult time looking across all 
requests/domains.


*educated in that I have experience building data sets out of ticketing 
systems.

Graeme
_________________________
Graeme Bunton
Manager, Management Information Systems
Manager, Public Policy
Tucows Inc.
PH: 416 535 0123 ext 1634



------ Original Message ------
From: "Williams, Todd" <Todd.Williams at turner.com>
To: "Graeme Bunton" <gbunton at tucows.com>; "Keith Kupferschmid" 
<keithk at SIIA.net>; "PPSAI WG" <gnso-ppsai-pdp-wg at icann.org>
Sent: 9/22/2014 5:12:57 PM
Subject: RE: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG 
call earlier today

>Thanks Graeme.  I want to make sure I understand your point on 
>Questions 4 and 5 – which are basically just asking p/p providers for 
>statistics on how often they disclose customer/beneficial user 
>information to third-party complainants (percentage-wise), and who 
>those complainants are (LEA, 3P IP complainants, etc.).
>
>
>
>Are you saying that if I as a customer ask my p/p provider how many 
>times they’ve disclosed my contact information to complainants – and if 
>so, to whom – most providers would respond that it’s exceedingly 
>difficult to track that information, and that therefore they don’t 
>know?
>
>
>
>From:gnso-ppsai-pdp-wg-bounces at icann.org 
>[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Graeme Bunton
>Sent: Monday, September 22, 2014 4:50 PM
>To: Keith Kupferschmid; PPSAI WG
>Subject: Re: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the 
>WG call earlier today
>
>
>
>Hi Keith,
>
>
>
>We've seen descriptions of their processes from GoDaddy, Tucows and 
>Endurance.
>
>
>
>What I think should be inferred though from our discussions and from 
>those descriptions is that there are no established standards for 
>disclosure because they are exceedingly difficult to craft.  In many 
>respects, standards would make the jobs of our compliance teams 
>significantly easier. However, in our years of doing business we have 
>never come to a place where we've found a set of rules that we can 
>apply to the variety of requests that we get.
>
>
>
>This working group is attempting to codify rules (in a relatively short 
>time frame) that service providers haven't been able to achieve 
>individually.  This isn't to say we shouldn't try, but it's clearly not 
>easy.  There are few black and white cases, and unending reams of gray 
>requests, which is why we've heard so much about providers protecting 
>their ability to exercise discretion.
>
>
>
>As for the below questions:
>
>
>
>1. I think I answered this previously in my description of our service.
>
>2. is an idea we had previously considered, 'self-requested take-down' 
>might be something we offer pending the outcome of this WG
>
>3. We do not have one for private 3rd parties. Excluding LEA and UDRP
>
>
>
>4. & 5.  Answers to these require the provider to be using some sort of 
>ticketing/request system that allows tagging/categorization and 
>reporting based on outcomes.   Many may not be big enough to have this 
>sort of system in place, or have systems that don't offer these 
>features.   This is probably exceedingly difficult information to 
>capture.
>
>
>
>Graeme
>
>_________________________
>
>Graeme Bunton
>
>Manager, Management Information Systems
>
>Manager, Public Policy
>
>Tucows Inc.
>
>PH: 416 535 0123 ext 1634
>
>
>
>
>
>
>
>------ Original Message ------
>
>From: "Keith Kupferschmid" <keithk at SIIA.net>
>
>To: "Mary Wong" <mary.wong at icann.org>; "PPSAI WG" 
><gnso-ppsai-pdp-wg at icann.org>
>
>Sent: 9/22/2014 1:58:36 PM
>
>Subject: Re: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the 
>WG call earlier today
>
>
>
>>My apologies if I missed something, but I have not seen any responses 
>>to the questions posed below.  I think it would be very helpful if the 
>>P/P providers could respond to these questions prior to tomorrow’s 
>>meeting if at all possible.
>>
>>
>>
>>Keith Kupferschmid
>>
>>
>>
>>From:gnso-ppsai-pdp-wg-bounces at icann.org 
>>[mailto:gnso-ppsai-pdp-wg-bounces at icann.org] On Behalf Of Mary Wong
>>Sent: Tuesday, September 16, 2014 6:38 PM
>>To: PPSAI WG
>>Subject: [Gnso-ppsai-pdp-wg] Questions for P/P providers from the WG 
>>call earlier today
>>
>>
>>
>>Dear WG members,
>>
>>
>>
>>With the Chairs’ consent, I’m sending on the questions that were asked 
>>by several WG members during the call earlier today, in the hopes that 
>>those members who are or know of P/P providers and their practices can 
>>respond. If links to or copies of provider practices and policies can 
>>be provided, that would be very helpful too.
>>
>>What are provider practices regarding customer notification when a 
>>disclosure request is received, and is the customer given the 
>>opportunity to respond? (Note - on the call, James had agreed to 
>>provide information about DBP; Graeme and Michele had responded on 
>>behalf of their respective companies – perhaps other providers besides 
>>DBP can also step in here?)Does any provider offer its customer an 
>>option other than disclosure or publication, e.g. an opportunity to 
>>cancel the registration instead (i.e. what some WG members have 
>>mentioned as a “takedown”)?What are provider “standards" for 
>>determining disclosure to third parties? Can providers give the WG 
>>some general information about the percentage of requests for 
>>disclosure that are successfulFor Q4, do providers also have 
>>information about the type of claims those relate to e.g. If they are 
>>from LEA, 3P IP claim etc.?
>>As also noted on the call, the Chairs will discuss some of the 
>>responses and suggestions that were made, with a view toward hopefully 
>>offering some kind of summary or recommendation in time for the call 
>>next week.
>>
>>
>>
>>Thanks and cheers
>>
>>Mary
>>
>>
>>
>>Mary Wong
>>
>>Senior Policy Director
>>
>>Internet Corporation for Assigned Names & Numbers (ICANN)
>>
>>Telephone: +1 603 574 4892
>>
>>Email: mary.wong at icann.org
>>
>>
>>
>>
>>
>>
>>
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