FW: [council] Response from ICANN Compliance re. RAP recommendations
Sincerely, Zahid Jamil Barrister-at-law Jamil & Jamil Barristers-at-law 219-221 Central Hotel Annexe Merewether Road, Karachi. Pakistan Cell: +923008238230 Tel: +92 21 35680760 / 35685276 / 35655025 Fax: +92 21 35655026 <http://www.jamilandjamil.com/> www.jamilandjamil.com Notice / Disclaimer This message contains confidential information and its contents are being communicated only for the intended recipients . If you are not the intended recipient you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this message by mistake and delete it from your system. The contents above may contain/are the intellectual property of DNDRC, and constitute privileged information protected by attorney client privilege. The reproduction, publication, use, amendment, modification of any kind whatsoever of any part or parts (including photocopying or storing it in any medium by electronic means whether or not transiently or incidentally or some other use of this communication) without prior written permission and consent of DNDRC is prohibited. From: owner-council@gnso.icann.org [mailto:owner-council@gnso.icann.org] On Behalf Of Marika Konings Sent: 23 February 2011 13:48 To: council@gnso.icann.org Subject: [council] Response from ICANN Compliance re. RAP recommendations Dear All, Please find attached the response from ICANN's Compliance Department in relation to resolved #1 of the recently adopted motion on the Registration Abuse Policies Working Group Final Report (RESOLVED #1, the GNSO Council instructs ICANN Policy Staff to forward the two issues identified by the RAP IDT as having low resource requirements, WHOIS Access recommendation #2 and Fake Renewal Notices recommendation #1, to ICANN Compliance Staff for resolution. ICANN Compliance Staff is requested to provide the GNSO Council with its feedback on the two recommendations and proposed implementation in a timely manner). Pam Little, Interim Head of Contractual Compliance, is not available to participate in the Council meeting coming Thursday, but she is happy to take further comments / questions by email. In addition, she has indicated that she is available to discuss the response and any further questions in person with the Council during the weekend session at the ICANN meeting in San Francisco, if required. With best regards, Marika
Its starting to feel like Alice in Wonderland A Working Group spends countless hours debating VI, followed by the Board making its own decision based on experts rather than the community. We are informed that a Code of Conduct will resolve the issues and, not to worry, all the resources necessary for a fully-funded Compliance Department will be made available. Then the positions for the Head of Compliance plus two other officers remain unfilled for the better part of a year Now Pam Littles response to GNSO Council questions is scary (emphasis added): With regard to part b) of Recommendation 2, the RAA requires that registrars provide an interactive web page and a port 43 WHOIS access. As mentioned above, the Compliance department uses an automated tool to monitor registrar port 43 access obligations. However, the monitoring tool does not monitor web-based WHOIS obligations. Monitoring registrar compliance with web based WHOIS access requires a manual check of each the 970+ registrars websites, as the Compliance department currently does not have an automated monitoring tool. I wonder which compliance officer(s) spends their life on this task? In reality, not enough. So, as I now understand it, we will have a set of laws in the new Code of Conduct (pdp or staff generated?) that the vertically integrated entities will honorably abide by, left unchecked due to lack of staff and clearly structural issues vis-à-vis how ICANN monitors compliance. My head is spinning Is it just me? RA Ronald N. Andruff RNA Partners, Inc. _____ From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Zahid Jamil Sent: Thursday, February 24, 2011 11:44 AM To: 'Bc GNSO list ' Subject: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP recommendations Sincerely, Zahid Jamil Barrister-at-law Jamil & Jamil Barristers-at-law 219-221 Central Hotel Annexe Merewether Road, Karachi. Pakistan Cell: +923008238230 Tel: +92 21 35680760 / 35685276 / 35655025 Fax: +92 21 35655026 <http://www.jamilandjamil.com/> www.jamilandjamil.com Notice / Disclaimer This message contains confidential information and its contents are being communicated only for the intended recipients . If you are not the intended recipient you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this message by mistake and delete it from your system. The contents above may contain/are the intellectual property of DNDRC, and constitute privileged information protected by attorney client privilege. The reproduction, publication, use, amendment, modification of any kind whatsoever of any part or parts (including photocopying or storing it in any medium by electronic means whether or not transiently or incidentally or some other use of this communication) without prior written permission and consent of DNDRC is prohibited. From: owner-council@gnso.icann.org [mailto:owner-council@gnso.icann.org] On Behalf Of Marika Konings Sent: 23 February 2011 13:48 To: council@gnso.icann.org Subject: [council] Response from ICANN Compliance re. RAP recommendations Dear All, Please find attached the response from ICANN's Compliance Department in relation to resolved #1 of the recently adopted motion on the Registration Abuse Policies Working Group Final Report (RESOLVED #1, the GNSO Council instructs ICANN Policy Staff to forward the two issues identified by the RAP IDT as having low resource requirements, WHOIS Access recommendation #2 and Fake Renewal Notices recommendation #1, to ICANN Compliance Staff for resolution. ICANN Compliance Staff is requested to provide the GNSO Council with its feedback on the two recommendations and proposed implementation in a timely manner). Pam Little, Interim Head of Contractual Compliance, is not available to participate in the Council meeting coming Thursday, but she is happy to take further comments / questions by email. In addition, she has indicated that she is available to discuss the response and any further questions in person with the Council during the weekend session at the ICANN meeting in San Francisco, if required. With best regards, Marika
It sounds like the recommendation is indeed an increase in compliance demands, but no funding for an automated monitoring tool, and that sounds silly to some. However, often organizations, whether commercial or non, lag behind in developing such tools. BUT, this is helpful to our purposes of interacting related to budget, and my draft letter, which I hope to finalize and share with others tomorrow. Sorry for delay. But, thanks, Ron, for your efforts to keep this a focus... From: randruff@rnapartners.com To: zahid@dndrc.com; bc-gnso@icann.org Subject: RE: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP recommendations Date: Thu, 24 Feb 2011 15:32:03 -0500 It’s starting to feel like Alice in Wonderland… A Working Group spends countless hours debating VI, followed by the Board making its own decision “based on experts” rather than the community. We are informed that a Code of Conduct will resolve the issues and, not to worry, all the resources necessary for a fully-funded Compliance Department will be made available. Then the positions for the Head of Compliance plus two other officers remain unfilled for the better part of a year… Now Pam Little’s response to GNSO Council questions is scary (emphasis added): With regard to part “b)” of Recommendation 2, the RAA requires that registrars provide an interactive web page and a port 43 WHOIS access. As mentioned above, the Compliance department uses an automated tool to monitor registrar port 43 access obligations. However, the monitoring tool does not monitor web-based WHOIS obligations. Monitoring registrar compliance with web based WHOIS access requires a manual check of each the 970+ registrars’ websites, as the Compliance department currently does not have an automated monitoring tool. I wonder which compliance officer(s) spends their life on this task? In reality, not enough. So, as I now understand it, we will have a set of laws in the new ‘Code of Conduct’ (pdp or staff generated?) that the vertically integrated entities will honorably abide by, left unchecked due to lack of staff and clearly structural issues vis-à-vis how ICANN monitors compliance. My head is spinning… Is it just me? RA Ronald N. Andruff RNA Partners, Inc. From: owner-bc-gnso@icann.org [mailto:owner-bc-gnso@icann.org] On Behalf Of Zahid Jamil Sent: Thursday, February 24, 2011 11:44 AM To: 'Bc GNSO list ' Subject: [bc-gnso] FW: [council] Response from ICANN Compliance re. RAP recommendations Sincerely, Zahid Jamil Barrister-at-law Jamil & Jamil Barristers-at-law 219-221 Central Hotel Annexe Merewether Road, Karachi. Pakistan Cell: +923008238230 Tel: +92 21 35680760 / 35685276 / 35655025 Fax: +92 21 35655026 www.jamilandjamil.com Notice / Disclaimer This message contains confidential information and its contents are being communicated only for the intended recipients . If you are not the intended recipient you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this message by mistake and delete it from your system. The contents above may contain/are the intellectual property of DNDRC, and constitute privileged information protected by attorney client privilege. The reproduction, publication, use, amendment, modification of any kind whatsoever of any part or parts (including photocopying or storing it in any medium by electronic means whether or not transiently or incidentally or some other use of this communication) without prior written permission and consent of DNDRC is prohibited. From: owner-council@gnso.icann.org [mailto:owner-council@gnso.icann.org] On Behalf Of Marika Konings Sent: 23 February 2011 13:48 To: council@gnso.icann.org Subject: [council] Response from ICANN Compliance re. RAP recommendations Dear All, Please find attached the response from ICANN's Compliance Department in relation to resolved #1 of the recently adopted motion on the Registration Abuse Policies Working Group Final Report (RESOLVED #1, the GNSO Council instructs ICANN Policy Staff to forward the two issues identified by the RAP IDT as having low resource requirements, WHOIS Access recommendation #2 and Fake Renewal Notices recommendation #1, to ICANN Compliance Staff for resolution. ICANN Compliance Staff is requested to provide the GNSO Council with its feedback on the two recommendations and proposed implementation in a timely manner). Pam Little, Interim Head of Contractual Compliance, is not available to participate in the Council meeting coming Thursday, but she is happy to take further comments / questions by email. In addition, she has indicated that she is available to discuss the response and any further questions in person with the Council during the weekend session at the ICANN meeting in San Francisco, if required. With best regards, Marika
participants (3)
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Marilyn Cade -
Ron Andruff -
Zahid Jamil