[gtld-tech] RDE (Registrar Data Escrow) specs, verification, data handling

[Eduardo Alvarez]

Hello Thomas, 
For your questions about specific content requirements in registrar data escrow deposits, I suggest you submit your inquiry to globalSupport at icann.org directly so that it can be properly channeled.

As communicated by ICANN to accredited registrars back in June-2022, NCC group has indeed updated their registrar data escrow deposit verification process to cover the requirements from the Registrar Data Escrow Specifications (https://www.icann.org/en/system/files/files/rde-specs-09nov07-en.pdf) and since 1-July-2022, NCC has been including warning messages when the deposit is found to be non-conformant with such requirements.
 
The document available at https://www.icann.org/en/system/files/files/registrar-data-escrow-deposit-verification-26may22-en.pdf may be helpful in providing more details regarding the warning messages provided by NCC Group as a result of their deposit verification process.
 
 Hope this helps,
--Eduardo A.

-----Original Message-----
From: gtld-tech <gtld-tech-bounces at icann.org> on behalf of "Thomas Corte (COREhub support) via gtld-tech" <gtld-tech at icann.org>
Reply-To: "Thomas Corte (COREhub support)" <Thomas.Corte at knipp.de>
Date: Monday, June 20, 2022 at 10:20 AM
To: "gtld-tech at icann.org" <gtld-tech at icann.org>
Cc: "core-gateway at knipp.de" <core-gateway at knipp.de>
Subject: [gtld-tech] RDE (Registrar Data Escrow) specs, verification,	data handling

    Hello,

    lately we've received some new warnings in the response e-mails we're 
    receiving from our RDE Agent (IronMountain/NCC) after making a deposit.
    They seem to indicate that ICANN is starting a stricter verification of 
    the RDE CSV data than what was previously applied, to check compliance 
    with https://www.icann.org/en/system/files/files/rde-specs-09nov07-en.pdf 
    and a new document entitled "Registrar Data Escrow Guidelines" which 
    we've received from NCC but which doesn't seem to be published anywhere 
    online.

    In this context, we were wondering about some of the involved data 
    handling that seems to be implied by the verification messages, and what 
    other registrars on this list may be doing in this regard. In particular,


    1) Do you locally store the data of non-sponsored contact objects
    referenced by your domains?

    For thick registries, it is usually perfectly legal for a domain
    sponsored by registrar A to use a contact sponsored by registrar B, e.g. 
    after a transfer. Thanks to GDPR and other data protection policies, the 
    data of such foreign contact can usually not be inquired by the 
    non-sponsoring registrar, which makes its local storage impossible.
    Nevertheless, the Escrow guidelines seem to dictate that registrar A's 
    RDE deposits should include the data of registrar B's contact, which in 
    most cases cannot be known by registrar A. Of course, one way to solve 
    this would be to require registrars to only use their own contacts in all 
    of their domains, but this somewhat breaks the relation model between 
    domains and contacts (as obviously intended by the inventors of EPP) as 
    far as its cross-registrar application is concerned.


    2) How to you handle domains which are lacking certain contact types?

    The contact types for which some data is expected in the RDE deposit are 
    still the usual four: registrar, admin, tech, billing. However, some 
    gTLDs are no longer requiring billing contacts thanks to GDPR (they never 
    made much sense in the first place), and even admin and tech are 
    oftentimes no longer required (e.g., CentralNic doesn't seem to enforce 
    admin contacts anymore).


    If anyone from ICANN is reading this, any input would also be highly 
    appreciated, especially regarding the new document "Registrar Data Escrow 
    Guidelines" which seems to also introduce some new requirements regarding 
    proxy contacts.


    Generally, this could be a good opportunity to standardize, streamline 
    and modernize the RDE data format, which was so far highly 
    underspecified. Unfortunately, the new documents that popped up recently 
    (see above) are not helping with this issue, on the contrary: they are 
    creating even more uncertainty instead.

    Best regards,

    Thomas Corte
    on behalf of COREhub

    -- 
    --=== COREhub Technical Support ===-------------------------------------

           Thomas.Corte at knipp.de         Thomas Corte
                                         COREhub, IANA ID 15
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