Re: [ALAC] IRTP Part C implementation
Interesting. I agree that the PDP did not contemplate this particular case. But it is less than clear what the process is to fix it, if indeed a fix is required. I don't think the letter is entirely accurate, as it describes only the case of a P/P provider that is the Registrar itself. They may be the case in a large percentage of such registrations, but is not the only case. In fact, another of the IRTP PDPs spent a LOT of time focusing on cases where the P/P provider is unrelated to the registrar. I am going to reach out to James on this and will get back. I note that the letter refers to an attached Appendix A which outlines four use cases. The Appendix is not attached to the letter as posted by ICANN. Alan At 03/12/2016 05:17 PM, Rinalia Abdul Rahim wrote:
Dear ALAC,
The Board has received the following correspondence from the GNSO Council regarding IRTP Part C:
Please consider whether you wish to provide comment or advice to the Board and/or Staff.
Best regards,
Rinalia
-- Rinalia
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Thanks Alan My concern here is that the issue might be resolved by an Implementation team, with no ALAC members on it. You are correct in saying that the issue is not just about a change in the nature of service provided by one registrar. The other issue is when a customer of a P/P service wants to transfer to ANOTHER registrar. That issue was raised and talked through at length in a day long F2F meeting in LA. At the time, it was James who observed that maintaining the privacy details of a registrant in that situation is difficult because of the accuracy obligations on registrars under the RAA. And while we spent time on the issue, it was not resolved. So an implementation team is the not best place for resolution - it really is a policy issue. No sure where that takes us, but it is yet another wrinkle in the whole privacy discussion - and all the more reason for progress on the RDS WG Holly On 4 Dec 2016, at 9:53 am, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
Interesting. I agree that the PDP did not contemplate this particular case. But it is less than clear what the process is to fix it, if indeed a fix is required.
I don't think the letter is entirely accurate, as it describes only the case of a P/P provider that is the Registrar itself. They may be the case in a large percentage of such registrations, but is not the only case. In fact, another of the IRTP PDPs spent a LOT of time focusing on cases where the P/P provider is unrelated to the registrar.
I am going to reach out to James on this and will get back.
I note that the letter refers to an attached Appendix A which outlines four use cases. The Appendix is not attached to the letter as posted by ICANN.
Alan
At 03/12/2016 05:17 PM, Rinalia Abdul Rahim wrote:
Dear ALAC,
The Board has received the following correspondence from the GNSO Council regarding IRTP Part C:
https://gnso.icann.org/en/correspondence/bladel-to-crocker-01dec16-en.pdf
Please consider whether you wish to provide comment or advice to the Board and/or Staff.
Best regards,
Rinalia
-- Rinalia
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There are a number of issues. I suspect that the missing appendix gives additional details, so I see no purpose in a detailed analysis until we have it. What James is asking suggested that the P/P IRT is one possible path (one I suspect I would not favour upon further reflection) but also says that one of the new policy processes could be used. He also says discussions should include other interested parties. Alan At 03/12/2016 09:19 PM, Holly Raiche wrote:
Thanks Alan
My concern here is that the issue might be resolved by an Implementation team, with no ALAC members on it. You are correct in saying that the issue is not just about a change in the nature of service provided by one registrar. The other issue is when a customer of a P/P service wants to transfer to ANOTHER registrar. That issue was raised and talked through at length in a day long F2F meeting in LA. At the time, it was James who observed that maintaining the privacy details of a registrant in that situation is difficult because of the accuracy obligations on registrars under the RAA. And while we spent time on the issue, it was not resolved. So an implementation team is the not best place for resolution - it really is a policy issue.
No sure where that takes us, but it is yet another wrinkle in the whole privacy discussion - and all the more reason for progress on the RDS WG
Holly On 4 Dec 2016, at 9:53 am, Alan Greenberg <<mailto:alan.greenberg@mcgill.ca>alan.greenberg@mcgill.ca> wrote:
Interesting. I agree that the PDP did not contemplate this particular case. But it is less than clear what the process is to fix it, if indeed a fix is required.
I don't think the letter is entirely accurate, as it describes only the case of a P/P provider that is the Registrar itself. They may be the case in a large percentage of such registrations, but is not the only case. In fact, another of the IRTP PDPs spent a LOT of time focusing on cases where the P/P provider is unrelated to the registrar.
I am going to reach out to James on this and will get back.
I note that the letter refers to an attached Appendix A which outlines four use cases. The Appendix is not attached to the letter as posted by ICANN.
Alan
At 03/12/2016 05:17 PM, Rinalia Abdul Rahim wrote:
Dear ALAC,
The Board has received the following correspondence from the GNSO Council regarding IRTP Part C:
Please consider whether you wish to provide comment or advice to the Board and/or Staff.
Best regards,
Rinalia
-- Rinalia
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The issue was raised in the PPSAI IRT a couple weeks ago. If the objective is transfer [of ownership or economic rights], then every change to registrant data becomes material. The classification of the registration as having a P/P feature is one detail. So, the question is simple, will the P/P feature transfer with the registration? If so, what are the new details. I think the most that is required here is to ring-fence the material changes and insist that the recording and notification required as at Dec 1 be strictly enforced. In regard of a registration with P/P applied, the registrant at the time of transfer must confirm if a P/P detail goes with the change. That will constitute what we call in the regulatory practice a blackbox arrangement, the contents of the blackbox itself subject to rules already established. Or, conversely communicate an 'open' registration. I really cannot understand this kerfuffle about how to record this. -Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Planning, Governance, Assessment & Turnaround* ============================= On Sat, Dec 3, 2016 at 5:53 PM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
Interesting. I agree that the PDP did not contemplate this particular case. But it is less than clear what the process is to fix it, if indeed a fix is required.
I don't think the letter is entirely accurate, as it describes only the case of a P/P provider that is the Registrar itself. They may be the case in a large percentage of such registrations, but is not the only case. In fact, another of the IRTP PDPs spent a LOT of time focusing on cases where the P/P provider is unrelated to the registrar.
I am going to reach out to James on this and will get back.
I note that the letter refers to an attached Appendix A which outlines four use cases. The Appendix is not attached to the letter as posted by ICANN.
Alan
At 03/12/2016 05:17 PM, Rinalia Abdul Rahim wrote:
Dear ALAC,
The Board has received the following correspondence from the GNSO Council regarding IRTP Part C:
https://gnso.icann.org/en/correspondence/bladel-to-crocker-01dec16-en.pdf
Please consider whether you wish to provide comment or advice to the Board and/or Staff.
Best regards,
Rinalia
-- Rinalia
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participants (3)
-
Alan Greenberg -
Carlton Samuels -
Holly Raiche