[gnso-rds-pdp-wg] Possible Requirements from Privacy and Proxy Working Group Recommendations

[Susan Kawaguchi]

Hello All,

I have reviewed and pulled out a few PR’s from the PPSAI final report

Final Report on the Privacy & Proxy Services Accreditation Issues Policy Development Process
https://gnso.icann.org/en/issues/raa/ppsai-final-07dec15-en.pdf

[DE-Dxx-R01] To the extent feasible, domain name registrations involving P/P service providers should be clearly labelled as such in [the RDS].

[DA-Dxx-R01] P/P service customer data [should] be validated and verified in a manner consistent with the [registration data validation/verification] requirements outlined in the WHOIS Accuracy Program Specification of the 2013 RAA (as updated from time to time). Moreover, in the cases where a P/P service provider is Affiliated with a registrar and that Affiliated registrar has carried out validation and verification of the P/P customer data, re-verification by the P/P service provider of the same, identical, information should not be required.

The definition of law enforcement I think also needs to be tied to the RDS more explicitly. Perhaps that would be something like "For all users/purposes that involve law enforcement, this definition should apply:" <give definition>?

Hope this is helpful. When you are ready to submit the PRs, email them to the WG mailing list. Happy to eyeball first if you'd like to offer feedback on the questions you choose/framing.

The following definition for law enforcement is not a PR but thought the WG should note this as it was an agreed upon definition in the PPSAI WG and may be a helpful starting point if a definition is needed for the RDS.

Law enforcement authority means law enforcement, consumer protection, quasi- governmental or other similar authorities designated from time to time by the national or territorial government of the jurisdiction in which the P/P service provider is established or maintains a physical office. This definition is based on Section 3.18.2 of the 2013 Registrar Accreditation Agreement, which provision spells out a registrar’s obligation to maintain a point of contact for, and to review reports received from, law enforcement authorities65; as such, the WG notes that its recommendation for a definition of “law enforcement authority” in the context of privacy and proxy service accreditation should also be updated to the extent that, and if and when, the corresponding definition in the RAA is modified.

Susan Kawaguchi
Domain Name Manager
Facebook Legal

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