[IRT.RegDataPolicy] [Ext] Re: Additional Thoughts Re yesterday's Rec. 7 discussion

[Dennis Chang]

Dear Rubens,

I may be misunderstanding your message, but I wanted to clarify that the Thick policy is and has been in effect since 1 February 2019. This original effective date has not changed.
•  Thick RDDS (Whois) Transition Policy for .COM, .NET and .JOBS<https://www.icann.org/resources/pages/thick-whois-transition-policy-2017-02-01-en> (effective 1 February 2019, adopted by ICANN Board 7 February 2014; implementation documents posted 1 February 2017)

What may be confusing is the Contractual Compliance Enforcement dates for the policy. As noted on the News Box on the policy page:
“On 14 March 2019, the ICANN Board passed a Resolution to defer contractual compliance enforcement. ICANN Contractual Compliance will defer enforcing the following milestones until the dates listed below:
By 30 November 2019: The registry operator must begin accepting Thick WHOIS data from registrars for existing registrations in .COM, .NET and .JOBS.
By 31 May 2020: All registrars must send Thick WHOIS data to the registry operator for all new registrations in .COM, .NET and .JOBS.
By 30 November 2020: All registrars are required to complete the transition to Thick WHOIS data for all registrations in .COM, .NET and .JOBS.”

To date, I am not aware of any additional deferrals, and barring no further direction from the ICANN Board, the Policy Effective date has not changed.
I am the Program Director for the Thick Policy Implementation and have been notifying the Thick IRT each time there is an update.
I’ll be sure to make this clear on my next briefing to the GNSO Council.

Thanks for your contribution to the RegDataPolicy Implementation.

Dennis Chang

From: Rubens Kuhl <rubensk at nic.br>
Date: Thursday, August 8, 2019 at 10:21 AM
To: Margie Milam <margiemilam at fb.com>
Cc: Dennis Chang <dennis.chang at icann.org>, "IRT.RegDataPolicy" <irt.regdatapolicy at icann.org>
Subject: [Ext] Re: [IRT.RegDataPolicy] Additional Thoughts Re yesterday's Rec. 7 discussion



As a result, the new policy continues the “thick WHOIS” requirements and our implementation needs to be consistent with Thick WHOIS, especially in light of the Board’s resolution  and its anguage in the scorecard.


While I still have to do a more through analysis of the report and the board scorecard to see whether we need to add something to the Council-board dialog, we need to be mindful that we are in implementation area here. From an implementation standpoint, only CL&D (consistent labelling and display) part of the Thick WHOIS policy is already implemented. The thin-to-thick transition of .com, .net and .jobs is still pending, so no new policy implementation - including RegDataPolicy - can assume all registrations are thick. There are both thin and thick registration and they will continue to coexist for some time, and I don't read neither the policy or the scorecard as marching orders for the thin-to-thick transition. On the contrary, both seem very carefully constructed to not give such an impression.



Rubens



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