[Gnso-ppsai-pdp-wg] Language concerning the lock under IRTP-C and a "Change of Registrant"

[Mary Wong]

Dear WG members,

As requested during the WG call earlier today, here is the relevant language
in the Final Report recommendations which contains express references to the
IRTP-C.

The first reference appears in the WG¹s recommendation that P/P providers
publish as part of their Terms of Service certain information regarding
Publication of a customer¹s contact information. Among other things, a
provider must also include:
> "The specific grounds upon which a customer¹s details may be Disclosed or
> Published or service suspended or terminated, including Publication in the
> event of a customer¹s initiation of a transfer of the underlying domain name .
> In making this recommendation, the WG noted the changes to be introduced to
> the Inter Registrar Transfer Policy (³IRTP²) in 2016. These changes mean that
> disabling proxy services would result in the underlying customer becoming the
> registrant of record , as Section C.1.2 of the IRTP requires a registrar to
> impose a 60-day inter-registrar transfer lock following a Change of
> Registrant."


Given the recent discussions on the mailing list and the call today, the WG
may wish to consider rewording the above to say, for instance:
> 
> "The specific grounds upon which a customer¹s details may be Disclosed or
> Published or service suspended or terminated, including Publication in the
> event of a customer¹s initiation of a transfer of the underlying domain name .
> In making this recommendation, the WG noted the changes to be introduced to
> the Inter Registrar Transfer Policy (³IRTP²) in 2016 . These changes mean that
> , where following a Change of Registrant, disabling proxy services would
> result in the underlying customer becoming the registrant of record , as
> Section C.1.2 of the IRTP requires a registrar is required to impose a 60-day
> inter-registrar transfer lock following a Change of Registrant."
> 
> 

(NOTE: The footnote explaining what a Change of Registrant means (i.e. a
non-typographical, change to either the registrant name, organization or
email address) will be retained. However, specific references as to the
extent of discretion in determining, how a Material Change resulting in a
Change of Registrant is determined, and a general conclusion equating every
disabling of P/P services to a Change of Registrant will be omitted.)



The second reference is in the de-accreditation section. If the above
suggested edit is acceptable to the WG, there doesn¹t seem to be a reason to
change the current language, which reads:
> 
> "In addition to the three [de-accreditation] principles outlined above, the WG
> recommends specifically that, where a Change of Registrant (as defined under
> the IRTP) takes place during the process of de-accreditation of a proxy
> service provider, a registrar should lift the mandatory 60-day lock at the
> express request of the beneficial user, provided the registrar has also been
> notified of the de-accreditation of the proxy service provider.²

We hope this is helpful.

Thanks and cheers
Mary

Mary Wong
Senior Policy Director
Internet Corporation for Assigned Names & Numbers (ICANN)
Telephone: +1 603 574 4889
Email: mary.wong at icann.org





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