October 2017 - Gdd-gnso-ppsai-impl

Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call
by Sara Bockey Dec. 1, 2017

Dec. 1, 2017

Caitlin, Thanks for the revised docs. A few items at first glance that need to be revised, as I believe they have been discussion/raised before. I will take a closer look and follow up with additional edits, but in the meantime… 1. Edit the definitions of Proxy Service and Privacy Service to match the definitions provided in the Final Report/2013 RAA * The definitions of Privacy Service and Proxy Service reflect those in the 2013 RAA. * In this context, the 2013 RAA also defines “Registered Name” as a domain name within the domain of a gTLD, about which a gTLD Registry Operator (or an Affiliate or subcontractor thereof engaged in providing Registry Services) maintains data in a Registry Database, arranges for such maintenance, or derives revenue from such maintenance, and “Registered Name Holder” is defined as the holder of a Registered Name. * It’s noted that ICANN staff has replace “Registered Name Holder” with “Customer” in many instances, but I question the logic in that since it is inconsistent with the RAA. 1. Edit Sections 3.5.3.3. thru 3.5.3.6 to take into consideration GDPR requirements regarding consent. * Consent must be explicitly given for each purpose and can be withdrawn at any time and not a requirement for registration or use of the service. Therefore, 3.5.3.3. – 3.5.3.6 (at a minimum) are not compatible and must be revise. 1. Edit section 3.12.2, as it still contains new language that has been added since the IRT agreement on language in August. The first sentence in its entirety should be removed. * The section should start with “Well founded…” Additionally, the following sections need revision or at a minimum further discuss by the IRT 1. Edit Section 3.14 to remove the language re no automation. This is not feasible. This language must be removed: * Provider shall not use high-volume, automated electronic processes (for example, processes that do not utilize human review) for sending Requests or responses to Requests to Requesters or Customers in performing any of the steps in the processes outlined in the Intellectual Property Disclosure Framework Specification. 1. Edit Section 3.15 – Labeling – to remove excessive language. * Provider shall ensure that each Registered Name for which Provider is providing the Services is clearly labeled as such in the Registration Data Directory Service, as specified in the Labeling Specification attached hereto, and shall otherwise comply with the requirements of the Labeling Specification attached hereto. This language is duplicative and not necessary. Let’s not add unnecessary words to this already long document. If there are doing to be extra works, perhaps mention complying with applicable local laws in light of GDPR. sara bockey sr. policy manager | GoDaddy™ sbockey(a)godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Caitlin Tubergen <caitlin.tubergen(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Wednesday, October 25, 2017 at 4:44 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Dear Colleagues, Thanks so much for your participation on today’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/24+October+2017. During the call, we discussed an overview of the changes to the draft PPAA. Please note that ICANN proposed a deadline of Tuesday, 14 November for all comments, concerns, and edits to the draft PPAA. The changes from the last iteration, provided to the IRT in July, have been highlighted in the attached issues list. Please respond to the list if you would like to request a longer review period. During ICANN60, we will be presenting an overview of the P/P program’s status to the community. Attached, please find the slide deck for the presentation. To highlight a few notes from the IRT’s discussion this morning, we received feedback to: 1. Edit the definition of Working Group in Section 1.43, to specify that the Provider Stakeholder Group, if formed, shall only appoint the provider representatives of the Working Group, and the GNSO may appoint other members of the community. 1. Add back in the previously-deleted Code of Conduct language in Section 3.5.1. 1. Add back in the previously-deleted review provision in Section 7 of the Customer Data Accuracy Program Specification. If you believe the above items do not reflect the intent of the Working Group’s recommendations, please reply to the list by 14 November 2017. Thank you, and safe travels to those of you attending ICANN 60! Kind regards, Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen(a)icann.org

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Materials, action items from 17 Oct Privacy/Proxy IRT call
by Caitlin Tubergen Nov. 6, 2017

Nov. 6, 2017

Dear Colleagues, Thanks so much for your participation on today’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/24+October+2017. During the call, we discussed an overview of the changes to the draft PPAA. Please note that ICANN proposed a deadline of Tuesday, 14 November for all comments, concerns, and edits to the draft PPAA. The changes from the last iteration, provided to the IRT in July, have been highlighted in the attached issues list. Please respond to the list if you would like to request a longer review period. During ICANN60, we will be presenting an overview of the P/P program’s status to the community. Attached, please find the slide deck for the presentation. To highlight a few notes from the IRT’s discussion this morning, we received feedback to: Edit the definition of Working Group in Section 1.43, to specify that the Provider Stakeholder Group, if formed, shall only appoint the provider representatives of the Working Group, and the GNSO may appoint other members of the community. Add back in the previously-deleted Code of Conduct language in Section 3.5.1. Add back in the previously-deleted review provision in Section 7 of the Customer Data Accuracy Program Specification. If you believe the above items do not reflect the intent of the Working Group’s recommendations, please reply to the list by 14 November 2017. Thank you, and safe travels to those of you attending ICANN 60! Kind regards, Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen(a)icann.org

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Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call
by Darcy Southwell Oct. 24, 2017

Oct. 24, 2017

My apologies, but I won’t be able to attend today’s call due to travel obligations. Safe travels to all going to Abu Dhabi. Darcy From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Caitlin Tubergen <caitlin.tubergen(a)icann.org> Reply-To: <gdd-gnso-ppsai-impl(a)icann.org> Date: Friday, October 20, 2017 at 6:21 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Dear Colleagues, Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/17+October+2017. During the call, we discussed: (1) The attached PP Data Escrow Specification. The IRT members on the call were OK with the proposed Specification, as it is similar to what registrars use today. (2) The attached updated PPAA (PPAA_redline_10Oct). During the call, we discussed: · the definition of Working Group in section 1.43. Some members of the IRT proposed that if there is a Provider Stakeholder Group in the future, the Provider Stakeholder Group should only be permitted to appoint the Service Provider representatives of the Working Group, rather than all members of the Working Group. Other members of the IRT noted that because the contract is between ICANN and the Service Provider, the definition of Working Group should mirror the Working definition in the RA/RAA. We tried to strike a balance between these positions in the updated draft PPAA_redline_17Oct. · Section 3.12.2 – some members of the IRT expressed concern that the IRT had previously agreed to remove the “monitored 24 hours a day, seven days a week” language from 3.12.1 and 3.12.2 but to keep the “respond within 24 hours” language under 3.12.2. Please note the “monitored 24 hours a day, seven days a week” language has been removed from the latest draft, PPAA_redline_17Oct. · Section 5.2 the renewal provision – a member of the IRT asked if language should be added that Providers cannot renew under an old form of the PPAA if a new version or global amendment goes into effect. This concern seems to be addressed in Section 5.3 of the agreement, which deals with ICANN’s right to substitute an updated agreement. Additionally, if the P/P Consensus Policy were ever changed/amended, the Policy would supersede the corresponding provisions in the PPAA. · Section 5.5.2.4 – Section 5.5 provides reasons under which ICANN can terminate the Service Provider’s Agreement. A member of the IRT noted that “a pattern and practice of trafficking in or use of domain names identical or confusingly similar to a trademark or service mark of a third party in which the Customer has no rights or legitimate interest, which trademarks have been registered and are being used in bad faith” is a reason for termination of the agreement but is not something addressed in the application/background screening. Further to that feedback, the updated application (v6) adds this question as part of the background screening questions. On Tuesday, 24 Oct, we will continue discussing the PPAA. I have attached a list that details the changes to the PPAA. If you have any specific concerns prior to the call, please feel free to respond to the list. Kind regards, Caitlin -- Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen(a)icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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Materials, action items from 17 Oct Privacy/Proxy IRT call
by Caitlin Tubergen Oct. 21, 2017

Oct. 21, 2017

Dear Colleagues, Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/17+October+2017. During the call, we discussed: The attached PP Data Escrow Specification. The IRT members on the call were OK with the proposed Specification, as it is similar to what registrars use today. The attached updated PPAA (PPAA_redline_10Oct). During the call, we discussed: the definition of Working Group in section 1.43. Some members of the IRT proposed that if there is a Provider Stakeholder Group in the future, the Provider Stakeholder Group should only be permitted to appoint the Service Provider representatives of the Working Group, rather than all members of the Working Group. Other members of the IRT noted that because the contract is between ICANN and the Service Provider, the definition of Working Group should mirror the Working definition in the RA/RAA. We tried to strike a balance between these positions in the updated draft PPAA_redline_17Oct. Section 3.12.2 – some members of the IRT expressed concern that the IRT had previously agreed to remove the “monitored 24 hours a day, seven days a week” language from 3.12.1 and 3.12.2 but to keep the “respond within 24 hours” language under 3.12.2. Please note the “monitored 24 hours a day, seven days a week” language has been removed from the latest draft, PPAA_redline_17Oct. Section 5.2 the renewal provision – a member of the IRT asked if language should be added that Providers cannot renew under an old form of the PPAA if a new version or global amendment goes into effect. This concern seems to be addressed in Section 5.3 of the agreement, which deals with ICANN’s right to substitute an updated agreement. Additionally, if the P/P Consensus Policy were ever changed/amended, the Policy would supersede the corresponding provisions in the PPAA. Section 5.5.2.4 – Section 5.5 provides reasons under which ICANN can terminate the Service Provider’s Agreement. A member of the IRT noted that “a pattern and practice of trafficking in or use of domain names identical or confusingly similar to a trademark or service mark of a third party in which the Customer has no rights or legitimate interest, which trademarks have been registered and are being used in bad faith” is a reason for termination of the agreement but is not something addressed in the application/background screening. Further to that feedback, the updated application (v6) adds this question as part of the background screening questions. On Tuesday, 24 Oct, we will continue discussing the PPAA. I have attached a list that details the changes to the PPAA. If you have any specific concerns prior to the call, please feel free to respond to the list. Kind regards, Caitlin -- Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen(a)icann.org

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Materials, action items from 10 Oct Privacy/Proxy IRT call
by Caitlin Tubergen Oct. 18, 2017

Oct. 18, 2017

Dear Colleagues, Thanks so much for your participation on last week’s Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/10+October+2017. During the call, we discussed: The draft de-accredited Provider Transition Procedure, specifically in reference to how unresolved abuse complaints should be handled. In the updated (and attached) version, please refer to section 2.7, where a requirement for the terminating provider to transfer unresolved abuse complaints to the gaining provider upon termination has been added. This was a suggestion proposed by a member of the IRT. (Note: there is not a requirement for the gaining provider to process the abuse complaints on a shortened timeline.) Please let us know if you have any further feedback on the De-Accredited Provider Transition Procedure. The draft applicant guidebook/application: in the draft we discussed (version 4), the background check questions were changed to mirror the questions in the registrar accreditation application. Note to IRT: Please let us know if you believe this is in line with the WG’s recommendations. In the updated draft, we reverted to the language in the IP Framework (per feedback from some members of the IRT), and we added a question, per IRT feedback, asking applicants to inform ICANN if its principals/officers have previously been employed by an entity whose ICANN accreditation was involuntarily terminated by ICANN. Please see section 3.6 and section 6.10. A high-level overview of the changes to the updated PPAA draft: we will be discussing the updates in greater details in upcoming calls. For our call on Tuesday, October 17, we will be presenting the Data Escrow Specification (attached). You will have additional time to review and provide feedback on the Data Escrow Specification following the call. Following a summary of the Data Escrow Specification, we will be working through the updated PPAA. If there is anything in particular you would like to flag before the call, please respond via the list. Thank you! Best, Caitlin -- Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen(a)icann.org

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Re: [Gdd-gnso-ppsai-impl] Materials, action items from today's Privacy/Proxy IRT call
by Sara Bockey Oct. 17, 2017

Oct. 17, 2017

Hi Caitlin, I found our previous discussion on 3.12.1 and 3.12.2 – see item 1(a)-(d) below. It was noted that 3.12.2 would be acceptable if no changes were made to it. However, as noted today, it has indeed been changed. Hope this helps. Sara sara bockey sr. policy manager | GoDaddy™ sbockey(a)godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Amy Bivins <amy.bivins(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday, September 5, 2017 at 11:27 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials, action items from today's Privacy/Proxy IRT call Hi, All, Thanks for your attendance and participation on today’s Privacy/Proxy IRT call. If you were unable to attend, I encourage you to review the recording and materials posted on the wiki, https://community.icann.org/display/IRT/5+September+2017 Please provide any additional input you have on the topics discussed today (summary provided below) no later than next Monday, 11 September. Also, please identify any additional PPAA sections that you would like to discuss. We are nearing the end of the PPAA issues list. Once we complete this, if no further topics are raised, we will move on to other unresolved items in preparation for proceeding to public comment. Summary of today’s topics, questions and action items (updated issues list, with complete IRT input, attached): 1. 24/7 monitoring of abuse contact (See PPAA draft Section 3.13.1) * IRT member proposal: Remove requirement that abuse contact be monitored 24/7, as this was not in the Final Report * Background: this provision was modeled on the RAA; Section 3.13.2, provides that “Well-founded reports of Illegal Activity submitted to Provider’s designated Abuse contact must be reviewed within 24 hours by an individual who is empowered by Provider to take necessary and appropriate actions in response to the report, including reports of Abuse submitted by Persons and their representatives pursuant to the Intellectual Property Disclosure Framework Specification.” * IRT input received: Multiple IRT members supported deletion of the 24/7 monitoring requirement from Section 3.13.1. Some IRT members initially asked what the requirement would be instead, but upon consulting Section 3.13.2, said that this would be adequate so long as Section 3.13.2 does not change. * IRT action items: Please review sections 3.13.1 and 3.13.2 and provide any further input to the list. If no additional (or no contrary) input is received, the 24/7 monitoring requirement will be deleted from Section 3.13.1 in the next PPAA draft. * De-accreditation process proposal (attached) * Staff provided overview of this process proposal, which was modeled on registrar process, with modifications to accommodate Final Recommendations surrounding Customer notice and other factors. * Initial IRT feedback indicated that requiring terminating providers to notify customers may not be effective, as providers engaged in bad acts or that are out of business may not comply. * Alternative suggestions: i. Have ICANN access data escrow deposits for the purposes of identifying impacted customers (potential data protection issues here); ii. Have registrars attempt to notify customers with any information the registrar has available (issues surrounding unavailability of data); iii. Underlying issue—doing our best to notify customers vs absolute certainty that customers will be notified (may not be possible) * Additional IRT input is requested on all aspects of this proposal, particularly the issues raised on today’s call, surrounding customer notices (and possible ICANN access to escrow data for that purpose). 1. Next steps on data retention * Staff provided summary of IRT input to date and proposed course of action—keep requirements in PPAA draft as-is, pending completion of community’s work on GDPR issues, to avoid over-stepping or conflicts. Update PPAA requirements with anything new from GDPR work if GDPR work is completed prior to end of this IRT, or allow for amendments to PPAA immediately upon completion of GDPR work to account for results of community process. * IRT feedback: PPAA should ultimately incorporate results of GDPR work (apparent consensus here) i. Could language be added to PPAA in the meantime to allow for retention for longest period permitted under applicable law? ii. Could waivers previously granted to registrars under RAA be extended to PPs in same jurisdictions without need for new waiver applications? (1 IRT member was cautious about this approach) As always, if you would like to raise any other issues or feedback, please feel free to send to the list at anytime. I’ll send an agenda and relevant materials for next week’s meeting to the list by the end of this week. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins(a)icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>

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updated PPAA + documents for today's IRT call
by Caitlin Tubergen Oct. 10, 2017

Oct. 10, 2017

Dear Colleagues, Attached, please find the most recent redline version of the Privacy and Proxy Provider Accreditation Agreement. During today’s IRT call, I will provide an outline of the changes to guide your review and feedback in the upcoming weeks. We do not expect you to review and provide comments prior to today’s call, as you are just now receiving the document. I look forward to speaking to you in about an hour. In addition to the updated PPAA, we will continue discussing the De-Accredited Provider Transition Procedure (attached) and the provider application (attached). Thank you to Greg and Theo for your comments and questions on the draft application; we will discuss them during today’s call. Thank you! Best regards, Caitlin

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Re: [Gdd-gnso-ppsai-impl] updated PPAA + documents for today's IRT call
by Michele Neylon - Blacknight Oct. 10, 2017

Oct. 10, 2017

Caitlin et al A few comments I still maintain that the $4k / year fee for registrars that are already accredited with ICANN and paying fees is too high. In the PPA_redline document: 3.8.3 “all services” is way too broad and is unreasonable. This should be narrowed to specify that it refers solely to proxy / privacy 3.9 for “affiliated” entities can this be simplified and combined? We already have to do this for our registrar accreditation having to do it twice is likely to cause confusion and create unnecessary duplication 3.12.3 – while the language here might be sufficient I suspect it’ll cause headaches for those of us who are trying to comply with GDPR etc., and are removing PII records as quickly as we can. My main concern is that ICANN Compliance (and others) might come looking for data we no longer hold. I also don’t really understand why the data needs to be held for this long. There is a reference in Spec 7 to a waiver, but I can’t see it here. Specification 7 section 2 has a very complicated waiver process which seems to be conflating data retention with whois policy. Unless I’m missing something this could be simplified quite a bit. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ http://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 Personal blog: https://michele.blog/ Some thoughts: https://ceo.hosting/ ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow,R93 X265,Ireland Company No.: 370845 From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Caitlin Tubergen <caitlin.tubergen(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday 10 October 2017 at 13:39 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] updated PPAA + documents for today's IRT call Dear Colleagues, Attached, please find the most recent redline version of the Privacy and Proxy Provider Accreditation Agreement. During today’s IRT call, I will provide an outline of the changes to guide your review and feedback in the upcoming weeks. We do not expect you to review and provide comments prior to today’s call, as you are just now receiving the document. I look forward to speaking to you in about an hour. In addition to the updated PPAA, we will continue discussing the De-Accredited Provider Transition Procedure (attached) and the provider application (attached). Thank you to Greg and Theo for your comments and questions on the draft application; we will discuss them during today’s call. Thank you! Best regards, Caitlin

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Materials, action items from 3 October Privacy/Proxy IRT call
by Caitlin Tubergen Oct. 10, 2017

Oct. 10, 2017

Dear Colleagues, Thank you for your participation on the last Privacy/Proxy IRT call on Tuesday, 3 October. For those who could not attend, I encourage you to review the recording (https://participate.icann.org/p8dnkiub56v/) and materials on the wiki, https://community.icann.org/display/IRT/03+October+2017. I attached two documents for your review: The updated Applicant Guidebook/Application (v3) The updated De-Accreditation Procedure (v2) Notes on Updated Applicant Guide We received feedback from the IRT that the application process should be simplified, which included (1) consolidation of “tracks”, i.e., rather than four tracks, there should be two tracks: unaffiliated entities and affiliated entities; (2) a streamlined application, which includes only necessary long-form/essay questions and a “check box”, short form for the majority of questions. Further to that feedback, please review the next iteration (v3) of the Applicant Guidebook, with particular attention to Sections 5-6 (p. 10-11). Please provide any additional feedback to the list by Tuesday, 10 October. We will discuss any updates on our call next Tuesday. Notes on De-Accreditation Procedure Further to your feedback on the last call about de-accreditation, we removed the text in section 2.4.6 about a customer’s personal information being revealed in WHOIS following a termination of a P/P Provider to reflect the reality of a termination, which would involve a potential suspension (per the Whois Accuracy Program Specification (WAPS) as opposed to publication of underlying customer information in RDDS. A few members of the IRT expressed concern with treating the information as inaccurate and suspending names after 15 days, per the WAPS. We proposed to change that period to 30 days, i.e., following a termination of a P/P provider, the gaining provider/registrar would have 30 days to contact the customers to correct the inaccurate WHOIS information before potential suspension. Additionally, a member of the IRT expressed a concern as to which entity (the terminated or gaining provider) would be in charge of processing abuse complaints during terminations. Until the date of P/P provider is terminated, the terminating provider would be responsible for handling abuse tickets, as that entity would still be under contract. Following the termination date, the new provider would be responsible for processing abuse complaints. A member of the IRT noted a potential gap, where an individual/entity may file a complaint with the terminating entity, but if it is not responded to, it would need to file a new version of the same complaint with the gaining entity. If you have any suggestions about how this should be handled, please feel free to make suggestions to the list by Tuesday, 10 October. On our next call on Tuesday, 10 October, we will be discussing the proposed updates to the attached documents. I am also hoping to have the next iteration of the Accreditaiton Agreement to share with you early next week. Thank you again for all of your work on this! Best regards, Caitlin

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Materials, action items from last Privacy/Proxy IRT call
by Caitlin Tubergen Oct. 4, 2017

Oct. 4, 2017

Dear Colleagues, Thanks so much for your participation on the last Privacy/Proxy IRT call on Tuesday, 19 September. For those who could not attend, I encourage you to review the recording and materials on the wiki, https://community.icann.org/display/IRT/19+September+2017. A detailed account of the feedback received during the call is attached. In summary, the consensus of the group appeared to be that: ICANN org should provide the IRT with supporting cost data to facilitate the discussion surrounding proposed program fees; ICANN org should create a new draft of the accreditation application, transforming most if not all of the “essay”-type questions in sections 5 and 6 to “confirm the applicant will comply”-type questions; ICANN org should revisit the list of questions to consider which ones should, and should not, be required for registrar-affiliated applicants. The shift to confirmation-type questions may reduce the burden of these questions for affiliates. ICANN is working on these deliverables, and they should be ready to share with the IRT in a couple of weeks. In addition, I want to flag that one IRT member has recommended that we revisit the current definitions of “privacy service” and “proxy service” in the current guidebook and PPAA drafts. Non-substantive changes to these definitions from the Final Report, to conform to other defined terms in the agreement, were not opposed by any IRT member when this topic was previously discussed. However, if multiple IRT members would like to revisit this discussion, this will be added to the agenda for a future meeting. For our call next Tuesday, 3 October, we will be discussing the second draft de-accreditation process (attached). Please review prior to the call so that we can discuss the proposed changes in detail. If you are unable to attend the call, as some of you have noted, please feel free to provide feedback via the list prior to or following the call. Additionally, prior to the call, I will be providing an updated Privacy/Proxy Accreditation Agreement. While we will be not discussing the updates in detail on next week’s call, I will be providing a high-level overview of the changes to guide your review/discussion on future calls. Please let me know if you have any questions in the meantime. Best regards, Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Office: +1 310 578 8666 Mobile: +1 310 699 5326 Email: caitlin.tubergen(a)icann.org

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