1.     Inescapable Requirement: Definition of Roles

Each role must be defined in terms of the authority and responsibilities associated with the role.  This definition must be explicitly available to both the people fulfilling the role and the people interacting with the people in those roles.  Each person named in a role must be aware of being named and must agree to the obligations associated with the role.

The definition must also include an explicit statement of how the information about the person in the role will be disseminated.

Information about the registrant is provided by the Account Holder.  The Account Holder is effectively an agent of the Registrant and is the only authoritative source of information about the status of the registrant.

2.     Recommendation: Unknown Persons

In addition to definite status of Natural Person or Legal Person, the status of Unknown should be included in the design of the system.

#  If what is implied by the proposed status as "Unknown person" is implied as an option for the Registrant to choose to be 'unknown', as in the case of a Journalist who considers it dangerous even to list his or her Registrant details, even as a 'natural' person, then this is certainly a remarkable proposal. This could also work as a sub-category in the Registration database as data that has some difficulty in being identified as of or belonging to a legal or natural person, in which case the 'unknown' person is a temporarily unknown person.

3.     Recommendation: Additional Protection

In addition to whether the registrant is a Natural, Legal or Unknown Person, the status should also include an additional attribute regarding whether the registrant requires special privacy protection.

It is an open question as to whether additional privacy protection should be available to any registrant who wishes it or should require justification.  At the very least, to facilitate visibility into potentially harmful behaviors, Registrars should avoid unnecessary protection of registration data.

# This is very considerate and thoughtful. Would it be useful to interpret this proposal as a proposal for a sub-category of some sort which might make it possible even for 'legal' persons, otherwise required to disclose a little more information than 'natural' persons, to seek extraordinary exemptions due to some special needs, temporarily or long-term? If that be the case such special protection requests may have to be exceptional, as for instance, as in the case of 'witness protection'  (not exactly of this order,  but mentioned to suggest a high degree of special need) in some countries.  The request may have to be exceptional, and the process of granting such a request, while being swift, may have to be a high level process

#  comments on the go, on the above two points.

4.     Recommendation: Downgrading

Registrants should have the option of “downgrading” the level of protection for some or all of their data elements.

Registrars should have the option of implementing downgrading on a field by field basis or in groups of fields.

ICANN should establish a date certain for registrars to implement registrant option to downgrade the sensitivity of their registrations.

5.     Comment: Recourse

 If a person named in any role in a registration feels the data is incorrect or is being disseminated improperly, they have recourse via the Registrant.  Failing that, they have recourse through ICANN’s compliance process.  No additional processes are required.

6.     Recommendation: Org Field

The Org field should not be used to determine the registrant’s status.  The Registrar should require Legal Persons to provide the Org data element.  The Registrar should permit Natural or Unknown registrants to provide or not provide the Org data element.

7.     Recommendation: Transition

ICANN should establish a plan for transitioning Unknown registrations into known status.