[RDS-WHOIS2-Privacy-Proxy] Privacy/Proxy Services Subgroup call #3: Decisions Reached and Action Items

[Jean-Baptiste Deroulez]

Dear Privacy/Proxy Services subgroup members,

Following today’s subgroup call #3<https://community.icann.org/x/pYMpBQ>, please find below the identified action items and decisions reached:
DECISIONS REACHED
1) The subgroup will follow the RT's agreement to not relegislate PDPs. Can raise concerns but should not make recommendations to modify PDP WG's recommendations prior to implementation.
2) Grandfathering is not a concept for PP registered domains but should be taken up in the data accuracy and compliance reports
ACTION ITEMS
1) Volker to provide alternative text for Rec 10 Objective 6 referring to PPSAI PDP recommendation on CATEGORY B QUESTION 2, indicating this objective was taken into consideration in the PDP but it is not appropriate for the RT to comment on sufficiency of this until implementation is complete.
The PPSAI PDP recommendation:
WG Conclusion: The WG recommends that P/P service customer data be validated and verified in a manner consistent with the 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.
2) Additional issue related to grandfathering:
(a) Volker to draft language regarding accuracy trigger in 2013 RAA for consideration by RT when data accuracy report is discussed (this will not to be addressed in PP report as "grandfathering" does not apply to PP registered domains)
(b) Susan to revise Recommendation on grandfathering compliance in the Compliance Subgroup report to broaden it to include all policies and DN registrations
3) Volker to reword Issue #1 (cost/fees) as a brief comment but not a recommendation, since implementation is underway and it is not yet time to make any recommendation on this
4) Volker to reword Issue #2 (impact of GDPR) to clarify comment but make no recommendation
5)  Volker to propose text for an issue on Abuse noting that PP abuse may occur and that a future review should include examining the impact of PP services on abuse. Consider whether this should lead to a recommendation that this be examined within 2 years after implementation/effective date of the policy - and/or collection of data to enable review.
Kind regards,

Jean-Baptiste
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