September 2017 - Gdd-gnso-ppsai-impl

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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Using PPSAI to solve remaining IRTP-C issues
by Volker Greimann Sept. 27, 2017

Sept. 27, 2017

Completely off-topic, but I believe we should take a look at clarifying a few minor points still unresolved in IRTP-C where they directly relate to the provision of PP services. On the top of the list is obviously the question whether the activation or de-activation of the service should trigger the owner change process, as this also may influence or affect the ability of a provider to cut off the service when a registrant violates their terms, or in case of a UDRP where there is under current policy an option at the beginning of the UDRP to disable the service and disclose the registrant. This would probably be solved by including a single line of text in our resulting policy: "The act of activating or de-activating proxy or privacy services shall not be considered to constitute a change of registrant in the context of the ICANN transfer policy." -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann(a)key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann(a)key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.

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CANCELLED: PPSAI IRT meeting - Tuesday, September 26
by Caitlin Tubergen Sept. 26, 2017

Sept. 26, 2017

Hello, All, This is a quick note to let you know that due to ICANN Staff offsite departmental meetings next week, our next scheduled IRT meeting on Tuesday, September 26 will be cancelled. Please save the date for our next meeting, which will be Tuesday, October 3 at 14:00 UTC. I will be sending out further materials for your review early next week. I hope everyone has a nice weekend, and I believe I echo everyone’s sentiments in sending best wishes to Amy and her family while she is out on maternity leave – you will be missed, Amy! Best 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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Re: [Gdd-gnso-ppsai-impl] Agenda for tomorrow's privacy/proxy IRT call
by Margie Milam Sept. 19, 2017

Sept. 19, 2017

Hi- I am sorry, I won’t be able to attend today’s call. Margie 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: Monday, September 18, 2017 at 1:26 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda for tomorrow's privacy/proxy IRT call Hi, All, This is a reminder that we will continue to discuss draft v2 of the PP Applicant Guide on tomorrow’s IRT call. I’ll do a quick recap of the input we’ve received so far (including from this past week on the list) and then we will continue discussing the draft accreditation application and the fees proposal. Please come prepared with your comments and feedback—as this is our only topic we will have plenty of time to discuss. We should also have a more detailed list of the proposed evaluation criteria for the accreditation process ready to send to you soon—hopefully 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<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMFAg&…>

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Materials, action items from today's PP IRT meeting
by Amy Bivins Sept. 19, 2017

Sept. 19, 2017

Hello, All, Thanks so much for your active participation on today's Privacy/Proxy IRT call. The call recording, slides and chat transcript are available on the wiki, https://community.icann.org/display/IRT/12+September+2017. If you couldn't attend, I encourage you to review these, as we covered a lot of ground this week. In summary, with respect to data escrow, IRT members on the call said that in drafting the specification, we should keep the proposed requirements as open as possible and not attempt to create restrictions with respect to various types of provider/registrar/affiliate relationships. With respect to the accreditation application process, initial input from many IRT members was that the process may need to be simplified. With respect to accreditation criteria, some IRT members said that we are still requiring too much for affiliated providers; other IRT members said we may have cut too much for affiliated providers. We need as much feedback on this topic as possible, given that the views among IRT members appear to be quite mixed. We will continue discussing this topic next week. IRT Action Items Please provide any further input you have on the topics discussed on today's call, including (a) the data escrow questions presented by Francisco Arias, (b) the "initial application window" process and (c) the proposed affiliate categories for accreditation processing purposes, no later than next Monday, 18 September. Also, please continue reviewing the PPAA draft v1 and send any additional topics that you would like to discuss to the list (we have several topics to revisit, but once we reach the end of the list, we will move on if no other topics are raised). Next week, we will continue discussing the second draft of the applicant guide, including any feedback you have on the topics discussed this week, plus the application questions and fees proposal. To aid this discussion, I am attaching an editable word version of the document, which Volker requested, so that proposed edits can be marked on the document. Please mark any proposed edits in track changes mode-this is how we will identify proposed changes to discuss with the group. If you have questions or comments, please don't hesitate to reply to the list. 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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Agenda for tomorrow's privacy/proxy IRT call
by Amy Bivins Sept. 18, 2017

Sept. 18, 2017

Hi, All, This is a reminder that we will continue to discuss draft v2 of the PP Applicant Guide on tomorrow's IRT call. I'll do a quick recap of the input we've received so far (including from this past week on the list) and then we will continue discussing the draft accreditation application and the fees proposal. Please come prepared with your comments and feedback-as this is our only topic we will have plenty of time to discuss. We should also have a more detailed list of the proposed evaluation criteria for the accreditation process ready to send to you soon-hopefully 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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Re: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting
by Margie Milam Sept. 12, 2017

Sept. 12, 2017

Hi- I am sorry I cannot make today’s meeting. I’ll catch up on email, and listen to the recording. All the best, Margie 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: Friday, September 8, 2017 at 7:55 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting Dear Colleagues, Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it. On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you’ll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We’ve also added a fees proposal. Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list. Have a great weekend! 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<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMFAg&…>

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Re: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting
by Michele Neylon - Blacknight Sept. 11, 2017

Sept. 11, 2017

Amy Thanks for sharing this. I have several concerns. Firstly the fees that are being proposed. I cannot understand why or how ICANN can justify charging $4k / year for this to a provider. From our perspective this makes zero sense, as there is no value being provided by ICANN and the cost is very high – you’re essentially doubling how much I pay ICANN per year. Background screening – this seems to be complete overkill for an “affiliated” provider. In our case for example ICANN is going to be dealing with the same person you’ve always dealt with. If you insist on subjecting us to this kind of scrutiny I don’t mind, but I just see it as being a waste of resources. 6.5 – I thought there was no clear agreement on different labelling of whois privacy in whois? 8.3 – where on earth did that come from? 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 Amy Bivins <amy.bivins(a)icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Friday 8 September 2017 at 14:55 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials for 12 Sept PP IRT Meeting Dear Colleagues, Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it. On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you’ll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We’ve also added a fees proposal. Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list. Have a great weekend! 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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Materials for 12 Sept PP IRT Meeting
by Amy Bivins Sept. 11, 2017

Sept. 11, 2017

Dear Colleagues, Our next Privacy/Proxy IRT meeting is scheduled for this upcoming Tuesday, 12 September at 1400 UTC. I hope you all can make it. On this call, I will walk you through the updated Applicant Guide, and then there will be time for Q&A and your feedback on the document. The most significant changes you'll note in this discussion draft v2 is a proposed streamlining of the application for providers that are affiliated with an ICANN-accredited registrar, privacy/proxy provider (not applicable in the initial application window), or a gTLD registry operator. We've also added a fees proposal. Please review prior to our meeting, and we look forward to discussing on Tuesday. Please share any feedback you have prior to our call on-list. Have a great weekend! 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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Materials, action items from today's Privacy/Proxy IRT call
by Amy Bivins Sept. 5, 2017

Sept. 5, 2017

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. 2. 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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