May 2018 - Gdd-gnso-ppsai-impl

PP fees proposal document attached
by Amy Bivins June 14, 2018

June 14, 2018

Dear Colleagues, Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list. Thank you for your patience. 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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PP IRT canceled next week, status update
by Amy Bivins May 24, 2018

May 24, 2018

Dear Colleagues, The PP IRT meeting scheduled for 29 May is canceled. We expect to have an update/answer to the communications to ICANN org, requesting a pause of this group's work, to be published next week. In the interim, I can report that ICANN is reviewing all of the proposed accreditation program materials, including against the Temporary Specification, and will bring any issues that arise back to the IRT for discussion. Following any additional feedback from you on the proposed next steps on the data escrow specification (requested deadline of tomorrow, 25 May), we will finalize the data escrow-related materials for distribution and feedback. Thanks, and 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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PP IRT question, no meeting Tues, fees info to be distributed shortly
by Amy Bivins May 21, 2018

May 21, 2018

Dear Colleagues, This week's PP IRT meeting will be canceled, as the issues on our to-do list this week can be addressed without a call. We have one question for you, below. Please consider this issue and provide your comments on this no later than 28 May. I hope to be able to update you later this week on the status of the RrSG request (received by ICANN 4 May) to pause this IRT's work (and the COA's letter in opposition). I also expect to be able to send the fees-related documentation to you within the next couple of days. Background The IRT has recommended that, with respect to the data escrow specification, Privacy and Proxy service providers that are affiliated with an ICANN-accredited registrar should be able to meet their data escrow deposit obligations through the registrar (so the registrar would deposit the PP registration data and underlying customer data, similar to the process currently followed under the interim RAA specification). In order to achieve this result, ICANN would need to make slight updates to the Registrar Data Escrow specification, to add two required data elements for the deposit (the privacy/proxy service provider ID and the domain ID). Question: Is this an acceptable result (updating registrar data escrow specification for PP-affiliated registrars that wish to have combined data escrow deposits), or should ICANN revert to having a completely separate data escrow specification that all PPs must deposit under, regardless of whether the PP is affiliated with a registrar or not? Please note that, regardless of the answer to this question, there will be a separate PP data escrow specification for (a) third-party providers and (b) providers that work with more than 1 registrar. Based on discussions thus far, we believe the intent was the former (updating the registrar specification) but we wanted to confirm before finalizing that proposed update to the registrar specification and distributing it to the designated data escrow agents to alert them to the proposed update. 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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New Temp Spec reference
by Volker Greimann May 18, 2018

May 18, 2018

As the new Temporary Spec now contains a direct obligation with regard to privacy services: /in the case of a domain name registration where a privacy/proxy service used (e.g. where data associated with a natural person is masked), Registrar MUST return in response to any query full WHOIS data, including the existing proxy/proxy pseudonymized email./ Correctly interpreted, this means that ICANN must offer a complete and up-to-date machine readable list of privacy services along with a reference of how to automatically recognize them as part of the accreditation program because otherwise there will be no way for registries and registrars of automatically setting their records to "display". Just another point in case why the TempSpec is deeply flawed. // -- 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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Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April
by Sara Bockey May 18, 2018

May 18, 2018

Regarding Section 4.2.2 “without limitations” is necessary to ensure legitimate instances not yet listed or thought of are covered. Examples of additional causes beyond the control of the Provider: war, terrorism, riots, power outage, internet outage, internet failure, server failure, foreign gov’t changes, labor disputes, etc. Regarding Section 4.2.2.5 – I see no issue with redundancy and there is no harm in including this. If anything, it protects against potential abuse (in parts of the world that are less democratic) Regarding Section 4.2.6 – Not redundant and 100% necessary. Particularly for providers in parts of the world that are less democratic. We must remember this will be applied globally. Belt and suspenders! At ICANN61 this addition gave registrars that spoke with me the most comfort. Finally, I note that Staff is using the 24-hr timeframe as the default in the document instead of one business day as agreed by the registrars. Since one business day is what the registrars have agreed to, should it not be the default until otherwise determined? sara bockey sr. policy manager | GoDaddy™ sbockey(a)godaddy.com<mailto:sbockey@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 <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, April 17, 2018 at 10:53 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT meeting--feedback requested by 27 April Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. For those who could not attend, I regret that we were unable to record this meeting (an issue with a new internal recording policy), but this was a one-time issue and all future meetings will be recorded. I’ve done my best to annotate the LEA specification document with the items we discussed, and have also attached the chat transcript. IRT Action Items We are nearing the completion of discussions on the LEA Specification. Other than the item of clear disagreement among members of the IRT—the time period for high priority requests—we are largely in the refining stage. To that end, we have a few final proposed edits for the group to review and comment on—including some edits that were originally suggested by Sara Bockey a few weeks ago and supported by many registrar members of the IRT. If we don’t hear any opposition to these edits that would warrant further discussion, we will make these edits as requested in the draft we publish for comment. Today, we considered whether the LEA Framework Specification would be clearer if we reorganized it slightly, to make more clear where processes apply to high priority requests and when they don’t. I’ve included two versions of the draft—the one with “orig” at the end of the title—which includes the proposed edits without reorganizing, and the “reorganized” one. Please review both and respond to the list with your thoughts about the proposed reorganizing of this. Please provide any additional input you have on this draft no later than next Friday, 27 April. Please note, specifically, questions in the following sections: Original Numbering Reorganized Version Section 2.1.10 (addition of “except in high priority” language at beginning of edit) Same section Section 3.2.1 (addition of the words “Standard Priority” to make clear this 2 business day receipt process doesn’t apply in high priority cases) Moved to Section 3.2.2 Section 4.2.2 (inclusion of “without limitations” language, plus input about and question from Steve Metalitz—any other reasons that registrars feel would be reasonable for refusing disclosure?); Also see feedback, generally, from PSWG liaison, in meeting chat transcript (most pasted into specification document but cuts off at the end) Same section Section 4.2.2.5 (is this redundant? ) Same section Section 4.2.6 (is this redundant?) Same section I’m also attaching the most recent draft de-accreditation procedure document. As mentioned on the list last week, upon further consideration on the ICANN org side we think we should add back in the proposed transition procedure for customers impacted by the de-accreditation or termination of a third-party provider (section 4). Please review and provide any further comments on this no later than 27 April. For next week, we are hoping to have the requested fees information ready for you to discuss. I’ll update you as soon as I can. 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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Response from COA to RrSG's request for PP IRT/AFAV pause received, posted to ICANN.org
by Amy Bivins May 11, 2018

May 11, 2018

Dear Colleagues, ICANN org received a letter yesterday from the Coalition for Online Accountability that responded to the RrSG's 4 May request that ICANN org pause the work of the PP IRT and the AFAV project. The letter is posted on ICANN org's correspondence page at https://www.icann.org/en/system/files/correspondence/marks-metalitz-to-atal… These communications are being evaluated. I'll provide an update re: status as soon as it is available. 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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No PP IRT meeting tomorrow
by Amy Bivins May 7, 2018

May 7, 2018

Dear Colleagues, We will not have a PP IRT meeting tomorrow because there are no new materials available to discuss. As noted in Xavier's message to the group on Friday, ICANN is working to finalize the additional fees-related materials and will provide an update to the group this week. The regularly-scheduled IRT meeting will also be canceled for next week, as many IRT members and staff will be attending the GDD Summit meeting. However, please watch your inboxes-I will send you anything we have that is ready for your feedback. In case you didn't see it, ICANN received a letter from the RrSG on Friday, recommending that this IRT's work be paused, https://www.icann.org/en/system/files/correspondence/bunton-to-atallah-04ma…. This recommendation is being evaluated, and I'll provide you an update as soon as I can. 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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Privacy and proxy services accreditation IRT - Fee evaluation - Follow up and update
by Xavier J. Calvez May 5, 2018

May 5, 2018

Dear IRT members, I am following up on the call held last week on the fee determination and the follow up actions we discussed. We have made good progress since last week’s call and are working towards completion. I am providing a status update on and some comments below. 1. Fee determination methodology: document the approach described verbally during the call last week – 80% complete. Need final review and editing. 2. PP accreditation application fee: provide breakdown of the cost estimate – 80% complete. Need to match the cost breakdown items to the list of activities provided, and perform final review. 3. PP annual accreditation fee: provide breakdown of the cost estimate – We had not included this topic in the original responses and we need to develop a response that provides an overall view of costing. The annual accreditation fee encompasses a much broader scope of activities than the more specific application process. As a reminder, the cost estimate is only one of the factors that contribute to the determination of a fee, and one that is used to corroborate the reasonableness of the fee levels considered, rather than a determining factor. We do understand that addressing this topic is the last open item before moving to the next step, and we are working diligently on completing the work on this matter, among several other priorities. We will provide an update on the above in course of next week. Thank you. Best, Xavier Xavier Calvez ICANN – SVP & CFO 12025 Waterfront Drive, Suite 300 Los Angeles, CA 90094 Phone: 310-301-5838 Mobile: 805-312-0052 Fax: 310-957-2348

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PP LEA Framework: Remaining items for IRT feedback (requested deadline 8 May)
by Amy Bivins May 1, 2018

May 1, 2018

Dear Colleagues, Upon reviewing your most recent feedback on the LEA Framework Specification, we have a couple of items left where there isn't a clear consensus among the members of the IRT. Please review this list this week and share any additional feedback you have no later than next Tuesday, 8 May. We can discuss on our scheduled call next week, if needed. I've attached the most recent markup, showing in redline only the comments on the sections where there is some disagreement among members of the IRT. For reference, those sections and issues are: Section 3.3.1 (time period for responses to high-priority requests)-it appears likely we will not obtain consensus on this item Section 4.1.2: The proposed addition of "without limitations," either here or moved to Section 4.1.4. Section 4.1.2.5.: The proposed addition of this section in its entirety. Section 4.1.6: The proposed addition of this section in its entirety, including whether this would be redundant or whether this should be incorporated elsewhere. 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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