- Gdd-gnso-ppsai-impl - lists.icann.org

Re: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday
by Sara Bockey April 16, 2018

April 16, 2018

Hi Amy, I hate to be nitpicky, I noticed in the revised LEA Spec you are stating that only Eric and Volker supported my proposal. Theo and Chris Pelling also noted their support. Please revise your records to accurately reflect this. Thanks, Sara 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: Wednesday, April 11, 2018 at 11:32 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday Dear Colleagues, Attached are updated documents for discussion on Tuesday’s Privacy/Proxy IRT call, at 1400 UTC: 1. Updated draft de-accreditation procedure 2. Updated LEA Framework Specification markup On our call Tuesday, I’ll walk you through the updates that have been made to the de-accreditation procedure based on your feedback. Please come prepared to discuss any further feedback you may have on this document, particularly the re-introduction of a proposed transition procedure that could be used to attempt to transfer impacted customers to a new provider if a provider is de-accredited. We considered whether to remove this process in the prior draft, due to practical concerns, but upon further consideration we think this process should be included, with the caveat that once it is tested adjustments may be needed to make the process work. For the updated markup of the LEA framework specification, the goal is to determine whether we have consensus among IRT members to adopt any of the changes proposed by registrar members of the IRT. There appears to be strong support for many of these proposed changes, so unless there is opposition to changes they can be incorporated into the draft. It’s clear that the 24-hour response time proposed by the PSWG for high-priority requests does not have consensus support of the IRT, so we plan to call out this section specifically during the public comment period for community feedback. I hope to also have an update for you on data escrow next week and, if not, soon thereafter. As Adobe Connect is still unavailable, Michelle will circulate alternative information for you to dial in for the meeting. 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] Items for PP IRT discussion on Tuesday
by Michele Neylon - Blacknight April 16, 2018

April 16, 2018

Amy I would hope that our repeated queries about the fee structure are addressed before Staff proceeds to put this out for public comment. 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 <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 16 April 2018 at 15:17 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday Dear Colleagues, This is a reminder that on tomorrow’s IRT call, we will be discussing the following: 1. any feedback you have on the current draft of the de-accreditation procedure (the change in this version of the draft is that we’ve added back in a draft ICANN-facilitated transition procedure that can be used to try to transition customers to a new provider in the event a provider is terminated). 2. the draft LEA disclosure framework specification. We will go through the most recent edits proposed by Sara Bockey and supported by many other registrars in the group to determine whether there is sufficient support in the IRT to incorporate these edits into the draft that will be published for public comment. We are planning to use the Zoom conferencing software for the call, and Michelle will be circulating login information to the list later today. If there are any issues with using Zoom, we will revert to using a phone bridge only, but are hoping to have Zoom so that we can review the LEA framework specification markup together in real time. As this is a new (to us) program, please long in early if you can to get a feel for how it works. Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Wednesday, April 11, 2018 2:32 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Items for PP IRT discussion on Tuesday Dear Colleagues, Attached are updated documents for discussion on Tuesday’s Privacy/Proxy IRT call, at 1400 UTC: 1. Updated draft de-accreditation procedure 2. Updated LEA Framework Specification markup On our call Tuesday, I’ll walk you through the updates that have been made to the de-accreditation procedure based on your feedback. Please come prepared to discuss any further feedback you may have on this document, particularly the re-introduction of a proposed transition procedure that could be used to attempt to transfer impacted customers to a new provider if a provider is de-accredited. We considered whether to remove this process in the prior draft, due to practical concerns, but upon further consideration we think this process should be included, with the caveat that once it is tested adjustments may be needed to make the process work. For the updated markup of the LEA framework specification, the goal is to determine whether we have consensus among IRT members to adopt any of the changes proposed by registrar members of the IRT. There appears to be strong support for many of these proposed changes, so unless there is opposition to changes they can be incorporated into the draft. It’s clear that the 24-hour response time proposed by the PSWG for high-priority requests does not have consensus support of the IRT, so we plan to call out this section specifically during the public comment period for community feedback. I hope to also have an update for you on data escrow next week and, if not, soon thereafter. As Adobe Connect is still unavailable, Michelle will circulate alternative information for you to dial in for the meeting. 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 meeting cancelled next week
by Amy Bivins April 6, 2018

April 6, 2018

Dear Colleagues, The privacy/proxy IRT meeting scheduled for next Tuesday, 10 April, has been canceled, because new materials are still being finzlied for IRT review. The several recent cancelations will impact our overall timeline and projected date for proceeding to public comment. We will provide updated materials for IRT review as soon as they are ready, and I hope to be able to update you next week on overall status/timeline issues. Thanks, and have a great weekend. 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] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins)
by Sara Bockey April 3, 2018

April 3, 2018

Amy, Following our F2F discussion on Sunday, many of us have continuing and renewed concerns regarding the LEA spec, in particular the high priority disclosure framework and Section 4.2. After much discussion and many options being put to staff, 4.1.2 has devolved to a “compromise” which is basically the exact same language we started with 6 months ago, with the exception of adding “in accordance with Section 4.2.” As such, we are very concerned that the LEA Spec as written creates a presumption of disclosure and means to bypass due process. Additionally, it is important to remember that this is an accreditation program for ALL Privacy/Proxy Providers around the globe. That means that LEA requests come from LEA in all sorts of countries, and the language in the accreditation agreement need to reflect that. We cannot take an American-centric view. We need to bolster the language in 4.2 to better protect the rights of the Provider and its customers. Therefore, if we are to consider/accept the current proposed high priority language, namely: “Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority.” Then the following amendments must be made to Section 4.2 (new language in bold below): 4.2. Disclosure: 4.2.1. Within the applicable timeframe for a request’s Priority Level, Provider will disclose to the LEA Requestor, using a secure mechanism (this must be defined), the Requested Information it holds [associated with] the account. 4.2.2. Disclosure can be reasonably refused by Provider for reasons consistent with the general policy stated herein, including without limitations any of the following: 4.2.2.1. The LEA Requestor failed to provide to Provider information to meet the minimum standard for acceptance as outlined in Section 2 of this Specification; 4.2.2.2. If disclosure would lead to a contravention of applicable law; or 4.2.2.3. Where the Customer has provided, or Provider has found, specific information, facts, or circumstances showing that disclosure will endanger the safety of the Customer. 4.2.2.4. Where Provider has requested a court order/warrant/subpoena and LEA Requestor was unable or unwilling to provide same. 4.2.2.5. Where Provider has not been able to verify the identity of the LEA Requestor. (We also need to determine how Providers can best verify the identity of the requestor in a timely fashion. This can at times be very time consuming.) 4.2.2.6. Where Provider has found, after investigation, that LEA Requestor’s request is not well founded. 4.2.3. If disclosure is refused by Provider, Provider must provide written notice (which may be by electronic communication) to the LEA Requestor setting for Provider’s specific reasons for refusing to disclose. Such notice must be provided by Provider to the LEA Requestor prior to any Customer notification by Provider, irrespective of the reason for refusal. 4.2.4. In exceptional circumstances, if Provider requires additional time to respond to the LEA Requestor, Provider shall inform the LEA Requestor of the cause of the delay and agree with the LEA Requestor on a new date by which it will provide its response under this Section. 4.2. 4.2.5. For all refusals made in accordance with the policy and requirements herein, Provider must accept and give due consideration to the LEA Requestor’s requests for reconsideration of the refusal to disclose. 4.2.6. Nothing in Section 4.2 above shall be interpreted nor is it intended to imply the Provider shall forego due process within its applicable jurisdiction to satisfy LEA Requestor’s request, regardless of Priority Level. Finally, I believe you were wanting to know if it was acceptable to have Escrow separate from the PPAA. I believe that is the case for the RAA, so I do not see an issue with having it separate from the PPAA. Sara 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: Sunday, March 11, 2018 at 6:24 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins) Dear Colleagues, Attached you will find a document that a member of the finance team will be discussing during our session starting in a few minutes. In addition, you’ll be hearing an update about ongoing discussions between registrar and PSWG members of the IRT related to the draft LEA disclosure framework specification. This language was discussed informally among a smaller group this afternoon. Registrar and PSWG members of the IRT appear to be nearing agreement on a proposal for presentation to the IRT that would include a 24-hour time frame for provider responses to high priority LEA requests, with some additional requirements for documentation demonstrating that the request is high priority. The updated draft language for Section 4.1.2 for further discussion (deletions shown as strikeouts, additions in blue) is currently: * “Where a disclosure request has been categorized as High Priority, this must be actioned responded to within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority.” In addition, staff was asked to provide suggestions for additional details that can be specified about what goes into a High Priority requests. Staff has proposed the following as a starting point. * “For High Priority requests, in addition to the requirements specified in Section 2.1.*, LEA Requesters should provide specific information demonstrating that the request is necessary due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation”. (Note: Section 2.1 is the section that lists all the details currently needed for a request.) We will be discussing these during the session and soliciting further feedback on the list afterward. 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 April 2, 2018

April 2, 2018

Dear Colleagues, As we are still working to finalize data escrow-related materials for you, we are cancelling tomorrow's IRT meeting. I'm hoping to be able to send the data escrow-related materials to you by mid-week, so that you have plenty of time to review before we discuss on our call next 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] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
by Darcy Southwell March 30, 2018

March 30, 2018

Amy, Given the edits and details below, and the March 30 deadline for further suggestions, what is staff’s expected timing for publishing for public comment? Thanks, Darcy 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> Date: Wednesday, March 28, 2018 at 5:40 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call. The fees information will not be ready for next week, but we will get it to you as soon as possible. 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 www.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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Re: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
by Michele Neylon - Blacknight March 29, 2018

March 29, 2018

Amy During a registrar specific meeting with Compliance in PR we asked specifically about their overall expected spend and the volume of complaints they currently handle related to privacy / proxy. Three things came out of this: 1 – Compliance does not see a large volume of complaints related to privacy / proxy 2 – Compliance has more staff budgeted for than they currently have 3 – they have no plans to increase their headcount Considering that the bulk of engagement from ICANN staff in relation to proxy / privacy is going to be around contractual enforcement I am really curious to see how ICANN intends to rationalise the proposed fees. 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 <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: Wednesday 28 March 2018 at 13:40 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov’t Agency [propose to change to “Law Enforcement Authority” here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of “subject to any additional requirements under applicable law or court order” in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I’m not sure whether the data escrow materials will be ready for next week or not. I’ll update you before we meet. If we don’t have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday’s call. The fees information will not be ready for next week, but we will get it to you as soon as possible. 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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Reminder: IRT feedback requested on proposed LEA Spec edits by EOD Friday, 30 March
by Amy Bivins March 28, 2018

March 28, 2018

Dear Colleagues, This is a reminder that you are requested to provide any additional input you have on the latest proposed edits to the LEA Specification no later than this Friday, 30 March. The latest message to the group on this topic is attached. The following proposed edits appear to be non-controversial given all of the IRT discussions to date. If we receive no objections to these proposals, we will add these to the draft prior to publishing for public comment: (1) The addition of the following sections proposed by Sara Bockey (information required to be included in an LEA request): 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that the Law Enforcement/Gov't Agency [propose to change to "Law Enforcement Authority" here for consistency] has attempted to contact the relevant parties and has no other means of identifying them. 2.1.11 For High Priority requests, in addition to the requirements specified in 2.1.1-2.1.10, the Requestor must provide specific information demonstrating that the request is High Priority due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation. We would also likely re-arrange this section slightly, to move the current section 2.1.7 (Any details otherwise required by applicable law) to the end of this section. (2) The addition of "subject to any additional requirements under applicable law or court order" in Section 4.3.1. (3) Moving section 6.3 up to the notification section as 4.3.3. The edits proposed in Section 4.2 appear to be more controversial and would be flagged during the public comment period. Likewise, the disagreement among IRT members on the time period for high-priority requests would be specifically flagged for public comment. If you would like to discuss any of these proposed edits during our call on Tuesday, please let me know. Internally, we are continuing to work on the request for additional data surrounding the fees proposal. We are also working on removing the data escrow specification from the body of the contract into a separate specification, and corresponding edits to the contract to accommodate that. I'm not sure whether the data escrow materials will be ready for next week or not. I'll update you before we meet. If we don't have updated escrow materials ready and you do not wish to discuss any of the LEA-related issues, we might cancel Tuesday's call. The fees information will not be ready for next week, but we will get it to you as soon as possible. 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 reporting specification, per IRT feedback
by Amy Bivins March 26, 2018

March 26, 2018

Dear Colleagues, Attached is an updated version of the reporting specification. To summarize the changes that were made: 1. We updated the report frequency to quarterly (initial proposal was monthly) 2. We eliminated the per-TLD report requirement 3. We eliminated a few of the unnecessary fields (e.g., publication requests for IP and LEA, some of the "total" fields at the top) 4. We added a couple of fields for "other" requests (non-LEA or IP) We have considered the IRT's feedback on use of RRI. ICANN org believes that the use of RRI is preferable for both ICANN org and providers, as opposed to accepting emailed forms because: * The only difference on the provider side is using an API (the report format will be the same, and ICANN is providing a template to create the CSV file that will be submitted via the API); * Using the API will allow real-time confirmation that the report format is valid, eliminating the need for manual communications back and forth between ICANN org and the provider * ICANN org will provide training materials for using the API for providers who are unfamiliar with the process. If you have any further feedback on this, please send it 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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IRT meeting canceled tomorrow, please send any final input on LEA spec by EOD Friday, 30 April
by Amy Bivins March 26, 2018

March 26, 2018

Dear Colleagues, Since we are still having issues with Adobe Connect, we are going to cancel tomorrow's Privacy/Proxy IRT meeting, as it would be difficult to review this document without a screen. Please send any final feedback on the proposed edits to this specification, raised by Sara and Nick, no later than your EOD Friday. I've attached the most recent markup that includes notes on proposed edits. 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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Discussion document for Tuesday's PP IRT meeting
by Amy Bivins March 24, 2018

March 24, 2018

Thank you, Sara. I’ve created a new markup of the spec showing the most recent comments and proposed edits from Sara Bockey and Nick Shorey (attached). We will go through this on Tuesday to determine whether there is consensus on any of these edits. If other registrars agree with Sara’s position on the 24 hour/1 business day issue, we will flag this as an area of disagreement among IRT members and specifically request public comments on this. I’m not sure yet whether we will have Adobe Connect capability restored in time for our meeting. If not, we will do the best we can with a phone bridge. Thanks, and have a great weekend. Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Thursday, March 22, 2018 4:30 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins) Hi Amy, After further discussions within our Legal team, we (GoDaddy) have determined that committing to a 24-hour response time for high priority requests is unworkable. Our P/P team does not, nor have they ever, provide a 24/7 service. Additionally, while GoDaddy, the registrar, has received “imminent threat to life” requests, our P/P team has not. Building this capability in our P/P would be a significant undertaking. And if this poses a challenge for a company as large as GoDaddy, it will be significantly more difficult for smaller providers. As Peter has often reminded us, this agreement is between the Provider and ICANN, and LEA is not a party to it. While we understand and respect the needs of LEAs, and GoDaddy has a long-standing track record of cooperating with high-priority investigations, that doesn’t mean we can accept unreasonable contract terms. Accordingly, after much consideration and internal discussions with our P/P and Legal teams, GoDaddy believes one business day is the appropriate response time for High Priority requests. Additionally, our Legal team has determined the following amendments are needed to the Specification. Section 2.1, the following provisions must be added: 2.1.9 A clear statement that the domain name or URL involved is part of an official investigation. 2.1.10 A clear statement that Law Enforcement/Gov’t Agency has attempted to contact the relevant parties and has no other means of identifying them. I would also like clarification to understand where ICANN staff is intending to include this proposed language: “For High Priority requests, in addition to the requirements specified in Section 2.1.*, LEA Requesters should provide specific information demonstrating that the request is necessary due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation”. Was staff intending it to be part of 2.1 or appear elsewhere? Regarding Nick’s comment on previously proposed language in 4.2.2.6, which states “Where Provider has found, after investigation, that LEA Requestor’s request is not well founded”, the intent to not to challenge the veracity of the request, but rather a reflection of the language that appears in Section 3.18.2 of the RAA. Regarding Nick’s comments on the proposed language in 4.2.2.4 and 4.2.6, while I appreciate his efforts to combine the two provisions as a compromise, 4.2.6 must stand on its own. I am willing to remove “Where Provider has requested a court order/warrant/subpoena and LEA Requestor was unable or unwilling to provide same” as a reason for refusal under 4.2.2, but the proposed 4.2.6 language must remain as is. In light of the above, 4.2.2 and 4.2.6 would read as follows: 4.2.2. Disclosure can be reasonably refused by Provider for reasons consistent with the general policy stated herein, including without limitations any of the following: 4.2.2.1. The LEA Requestor failed to provide to Provider information to meet the minimum standard for acceptance as outlined in Section 2 of this Specification; 4.2.2.2. If disclosure would lead to a contravention of applicable law; or 4.2.2.3. Where the Customer has provided, or Provider has found, specific information, facts, or circumstances showing that disclosure will endanger the safety of the Customer. 4.2.2.4. Where Provider has not been able to verify the identity of the LEA Requestor, in accordance with 3.2.2. 4.2.2.5. Where Provider has found, after investigation, that LEA Requestor’s request is not well founded. 4.2.6. Nothing in Section 4.2 above shall be interpreted nor is it intended to imply the Provider shall forego due process within its applicable jurisdiction to satisfy LEA Requestor’s request, regardless of Priority Level. Finally, I want to ensure that Staff includes a provision regarding exceptional circumstances, as previously discussed, to address acts of nature, or other circumstances outside of the provider’s control. Perhaps we can address this in Section 4.2.4, for example: 4.2.4. In exceptional circumstances, if Provider requires additional time to respond to the LEA Requestor, Provider shall inform the LEA Requestor of the cause of the delay and agree with the LEA Requestor on a new date by which it will provide its response under this Section. 4.2. 4.2.4.1. Exceptional circumstances to include delays caused by acts of nature. Sara 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<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Thursday, March 15, 2018 at 12:44 PM To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins) Thanks, everyone, for your continued work on this. Sara and other registrars in the group, what do you think about the issues/edits raised by Peter and Nick? I know it had been an incredibly busy week for those of you at ICANN61. It’s not expected that resolution must be reached on this this week. It’s clear that both sides are willing to continue working toward a compromise and hopefully we can pick this up on the list next week and wrap this up in our next meeting. With respect to the other major topic discussed this week, I’ll get you additional information as soon as I can regarding the fees discussion. Safe travels to everyone who attended ICANN61! Best, Amy Sent from my iPhone On Mar 15, 2018, at 1:36 PM, Nick Shorey <lists(a)nickshorey.com<mailto:lists@nickshorey.com>> wrote: Hi everyone, I suggest a couple of tweaks to the text amendments proposed by Sara, to provide further clarity: 4.2.2.4. Where a court order/warrant/subpoena is legally required and Requestor was unable or unwilling to provide the same; I think 4.2.6. is covered in 4.2.2 (it was certainly intended to achieve this, so maybe these two could be combined with something like: 4.2.2. If disclosure would lead to a contravention of applicable law, or require the Provider to act outside of due legal process within its required jurisdiction, irrespective of Priority Level. I’m not sure about the inclusion of 4.2.2.6. If the intent is to give the ability of the Provider to challenge the veracity of Request when appropriate legal authority (court order etc) has been provided I disagree, as I believe the judicial process should ultimately determine the veracity and legality of the prosecution’s evidential case, and I think it is a dangerous thing to shift the responsibility to the Provider to make such determinations. If the intent is to challenge the accuracy of the request, such as the domain name in question has been incorrectly spelt, or the privacy registration is not held with the Provider, then this should be covered in 4.2.2.1 and 4.2.3. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists(a)nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin<http://www.linkedin.com/in/nicklinkedin> Web: www.nickshorey.com<http://www.nickshorey.com> On 15 Mar 2018, at 17:08, Roman, Peter (CRM) <Peter.Roman(a)usdoj.gov<mailto:Peter.Roman@usdoj.gov>> wrote: All - I need some time to review and digest this, but my first reaction is that this is a good attempt to find a working compromise. That said, there is one provision that is mildly problematic: 4.2.2.4. Where Provider has requested a court order/warrant/subpoena and LEA Requestor was unable or unwilling to provide same. The whole point of the emergency request is that there is not enough time to get any kind of court order. If there was time to get a court order, we would just go get it. This provision would effectively render the high priority disclosure meaningless. Also, I was kind of hoping that rather than just denying requests outright, if the provider finds some problem, there could be a discussion between the provider and the Requestor about what those problems are and whether we can rectify them. I don’t know whether that can be incorporated in the draft but I hope that was an underlying assumption that I just missed in this quick review (while listening to the timeline discussion in San Juan). Finally, I don’t understand the bit about providers giving the LEA Requestor a written response. First, that seems slow in a situation where speed is critical (unless by “in writing” you mean “by email or text”). If you are going to deny the request, it would be good to do so in time to see if we can fix the issue and/or to work other avenues of investigation. Second, as noted above, that sounds like a final decision will be made without any consultation with the Requestor to try and fix the request. Thanks for taking the time to work on this with us and being willing to compromise. Best, Peter Roman Senior Counsel Computer Crime & Intellectual Property Section Criminal Division U.S. Department of Justice 1301 New York Ave.<x-apple-data-detectors://7>, NW Washington, DC 20530 (202) 305-1323 peter.roman(a)usdoj.gov<mailto:peter.roman@usdoj.gov> On Mar 15, 2018, at 12:30 PM, Sara Bockey <sbockey(a)godaddy.com<mailto:sbockey@godaddy.com>> wrote: Amy, Following our F2F discussion on Sunday, many of us have continuing and renewed concerns regarding the LEA spec, in particular the high priority disclosure framework and Section 4.2. After much discussion and many options being put to staff, 4.1.2 has devolved to a “compromise” which is basically the exact same language we started with 6 months ago, with the exception of adding “in accordance with Section 4.2.” As such, we are very concerned that the LEA Spec as written creates a presumption of disclosure and means to bypass due process. Additionally, it is important to remember that this is an accreditation program for ALL Privacy/Proxy Providers around the globe. That means that LEA requests come from LEA in all sorts of countries, and the language in the accreditation agreement need to reflect that. We cannot take an American-centric view. We need to bolster the language in 4.2 to better protect the rights of the Provider and its customers. Therefore, if we are to consider/accept the current proposed high priority language, namely: “Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority.” Then the following amendments must be made to Section 4.2 (new language in bold below): 4.2. Disclosure: 4.2.1. Within the applicable timeframe for a request’s Priority Level, Provider will disclose to the LEA Requestor, using a secure mechanism (this must be defined), the Requested Information it holds [associated with] the account. 4.2.2. Disclosure can be reasonably refused by Provider for reasons consistent with the general policy stated herein, including without limitations any of the following: 4.2.2.1. The LEA Requestor failed to provide to Provider information to meet the minimum standard for acceptance as outlined in Section 2 of this Specification; 4.2.2.2. If disclosure would lead to a contravention of applicable law; or 4.2.2.3. Where the Customer has provided, or Provider has found, specific information, facts, or circumstances showing that disclosure will endanger the safety of the Customer. 4.2.2.4. Where Provider has requested a court order/warrant/subpoena and LEA Requestor was unable or unwilling to provide same. 4.2.2.5. Where Provider has not been able to verify the identity of the LEA Requestor. (We also need to determine how Providers can best verify the identity of the requestor in a timely fashion. This can at times be very time consuming.) 4.2.2.6. Where Provider has found, after investigation, that LEA Requestor’s request is not well founded. 4.2.3. If disclosure is refused by Provider, Provider must provide written notice (which may be by electronic communication) to the LEA Requestor setting for Provider’s specific reasons for refusing to disclose. Such notice must be provided by Provider to the LEA Requestor prior to any Customer notification by Provider, irrespective of the reason for refusal. 4.2.4. In exceptional circumstances, if Provider requires additional time to respond to the LEA Requestor, Provider shall inform the LEA Requestor of the cause of the delay and agree with the LEA Requestor on a new date by which it will provide its response under this Section. 4.2. 4.2.5. For all refusals made in accordance with the policy and requirements herein, Provider must accept and give due consideration to the LEA Requestor’s requests for reconsideration of the refusal to disclose. 4.2.6. Nothing in Section 4.2 above shall be interpreted nor is it intended to imply the Provider shall forego due process within its applicable jurisdiction to satisfy LEA Requestor’s request, regardless of Priority Level. Finally, I believe you were wanting to know if it was acceptable to have Escrow separate from the PPAA. I believe that is the case for the RAA, so I do not see an issue with having it separate from the PPAA. Sara 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<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Sunday, March 11, 2018 at 6:24 PM To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: [Gdd-gnso-ppsai-impl] Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins) Dear Colleagues, Attached you will find a document that a member of the finance team will be discussing during our session starting in a few minutes. In addition, you’ll be hearing an update about ongoing discussions between registrar and PSWG members of the IRT related to the draft LEA disclosure framework specification. This language was discussed informally among a smaller group this afternoon. Registrar and PSWG members of the IRT appear to be nearing agreement on a proposal for presentation to the IRT that would include a 24-hour time frame for provider responses to high priority LEA requests, with some additional requirements for documentation demonstrating that the request is high priority. The updated draft language for Section 4.1.2 for further discussion (deletions shown as strikeouts, additions in blue) is currently: * “Where a disclosure request has been categorized as High Priority, this must beactioned responded to within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority.” In addition, staff was asked to provide suggestions for additional details that can be specified about what goes into a High Priority requests. Staff has proposed the following as a starting point. * “For High Priority requests, in addition to the requirements specified in Section 2.1.*, LEA Requesters should provide specific information demonstrating that the request is necessary due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation”. (Note: Section 2.1 is the section that lists all the details currently needed for a request.) We will be discussing these during the session and soliciting further feedback on the list afterward. 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/> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl <signature.asc> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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PP IRT action items, agenda for next week's meeting
by Amy Bivins March 21, 2018

March 21, 2018

Dear Colleagues, I hope you are well! Following up on the IRT's discussions during ICANN61, we have a couple of action items. Our next meeting is scheduled for 27 March, 1400 UTC. Registrar and PSWG members of the IRT are requested to provide any additional feedback on the LEA Disclosure Framework Specification discussion (most recent thread attached) prior to our next meeting. To recap, registrar members of the IRT indicated that they could potentially accept a 24-hour period for actioning high priority requests, provided other edits were made. PSWG provided feedback on those proposed edits. Feedback from registrar members of the group is specifically requested on the PSWG/LEA members' most recent response. We will have a final discussion on this topic on Tuesday, to determine whether or not a compromise can be reached. Per your feedback, ICANN org is finalizing an updated reporting specification draft, which I hope to be able to distribute to you this week. We're also working on edits to the data escrow spec, which we hope to be ready to discuss shortly. We are reviewing your feedback on fees with the Finance team and will provide an update next 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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Update, action items following PP IRT meetings at ICANN61
by Amy Bivins March 16, 2018

March 16, 2018

Dear Colleagues, I hope you are well. If you were unable to attend the ICANN61 privacy/proxy IRT face-to-face meeting in person or listen in, I encourage you to review the recording, available here: https://participate.icann.org/p4gkq5rzjbj/ Below, you will see a list of outstanding items, as well as a call for your feedback. Please review carefully. We are requesting your final feedback on items (1)-(2) by this Friday. During the session on Sunday, the IRT heard a presentation from ICANN org finance regarding the proposed fee schedule. ICANN is reviewing the IRT's request for additional supporting data and intends to provide a response next week. The IRT heard an update on discussions between PSWG and registrar members of the IRT on the LEA Disclosure Framework Specification. PSWG and registrar members continue to discuss this topic this week, with the goal of determining whether a compromise can be reached by this Friday. IRT Action Items 1. Request for feedback on draft reporting specification, per discussion on the list. Any additional IRT feedback is requested by the end of this week. We will draft any updates in response to your feedback early next week. * The most significant issue appears to be the level of detail that should be required for the reports. Registrar members of the IRT have asserted that it will be difficult to provide the level of detail proposed (or that these could be prone to human error in reporting)-regarding types of requests (LEA, IP, Other) and reporting by-registrar and by-TLD. Any additional feedback is specifically requested on this topic this week. A decision will be made on this after the close of ICANN61, for the purpose of drafting final proposed requirements for public comment. * There were issues raised about using the RRI reporting system versus allowing forms to be emailed. ICANN provided additional details (attached) on the RRI process (creating spreadsheet using standard format, converting to CSV, and submitting using API). The RRI process would be largely the same using an emailed form (the only difference would be emailing the CSV or spreadsheet rather than using the API). Considering the benefits of using RRI (less manual review of reports, immediate notifications to providers if there are problems with the report, less back-and-forth to correct report errors) ICANN proposes to keep the RRI requirement absent significant opposition to this from the IRT. Training for how to use the RRI system can be provided for providers who need it. 2. A question on the data escrow specification: Does the IRT see an issue with making the data escrow specification a separate document from the PPAA, so that it can be more easily updated if/when technical requirements change (as is done for registrars)? 3. Any additional IRT feedback on updated PPAA draft (attached) requested by 23 March. Our next IRT meeting is scheduled for 27 March, 1400 UTC. 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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Discussion items for today's PP IRT face-to-face at ICANN61 (starting in 10 mins)
by Amy Bivins March 11, 2018

March 11, 2018

Dear Colleagues, Attached you will find a document that a member of the finance team will be discussing during our session starting in a few minutes. In addition, you'll be hearing an update about ongoing discussions between registrar and PSWG members of the IRT related to the draft LEA disclosure framework specification. This language was discussed informally among a smaller group this afternoon. Registrar and PSWG members of the IRT appear to be nearing agreement on a proposal for presentation to the IRT that would include a 24-hour time frame for provider responses to high priority LEA requests, with some additional requirements for documentation demonstrating that the request is high priority. The updated draft language for Section 4.1.2 for further discussion (deletions shown as strikeouts, additions in blue) is currently: * "Where a disclosure request has been categorized as High Priority, this must be actioned responded to within 24 hours, in accordance with Section 4.2. The LEA Requester will detail the threat type and justification for a request with a Priority Level of High Priority." In addition, staff was asked to provide suggestions for additional details that can be specified about what goes into a High Priority requests. Staff has proposed the following as a starting point. * "For High Priority requests, in addition to the requirements specified in Section 2.1.*, LEA Requesters should provide specific information demonstrating that the request is necessary due to an imminent threat to life, serious bodily injury, critical infrastructure or child exploitation". (Note: Section 2.1 is the section that lists all the details currently needed for a request.) We will be discussing these during the session and soliciting further feedback on the list afterward. 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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Additional Background Re: Proposed PP Reporting Process
by Amy Bivins March 11, 2018

March 11, 2018

Dear Colleagues, Following up on our discussion today about the processes for monthly reporting, I can now provide some additional information from our tech team. I have attached two templates that can be used to get a better idea of how the report contents are expected to look (using RRI) assuming 2 sample registrars and TLDs. These templates were created using our current internal working draft, so the fields don't match the previous version of the specification you reviewed. Certain fields (in the top row) were tentatively deleted, and others added, pending further IRT input on the topic. If the IRT's consensus was that reporting should not be broken out by category, the number of fields would be further reduced. Providers would not be required under the current proposal to automate their end of the reporting and are allowed to generate the files manually if they prefer. Since RRI is a RESTful API, users may upload the report files using a simple command line, or even public web browser extensions that allow users to execute HTTP PUT requests as a REST Client. For example, in a Unix based terminal this can be done by running the following commands replacing the highlighted fields with the corresponding value for the Provider credentials, file name, provider ID and reported date: * Upload Per Registrar report: curl -u username:password --header "Content-Type:text/csv" --request PUT --data-binary @PPSP-registrars-yyyymm.csv --dump-header - <base-url>/report/ppsp-activity-registrar/PPSP-ID/2018-03 * Upload Per TLD report: curl -u username:password --header "Content-Type:text/csv" --request PUT --data-binary @PPSP-tld-yyyymm.csv --dump-header - <base-url>/report/ppsp-activity-tld/PPSP-ID/2018-03 Some REST clients for browsers have similar looks to the screenshot below added for reference to show the ease of use, however ICANN does not provide support for third party software. [cid:image001.jpg@01D3B55A.2B813B10] Please let me know should there be any other questions. 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] Action items from today's IRT call
by Sara Bockey March 11, 2018

March 11, 2018

Amy, It seems clear that the additional language is necessary regardless of 4.2. It’s been raised repeatedly and agreed to by pretty much all of the registrars, so it’s unclear to me why you keep trying to remove it. Additionally, it has been raised repeatedly and agreed to my pretty much all of the registrars that the 3 instances under 4.2.2 are not sufficient. There are extraordinary circumstances that could arise, as outlined previously. At the very least, we need to amend the language to say “including but not limited to”. It’s incredibly frustrating that staff does not appear to hear what we are saying. Sara 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: Thursday, March 8, 2018 at 8:04 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Thanks, Lindsay! I’ll note that in Section 4.2 (I’ve attached a copy of the specification as it looks now, with no changes), disclosure may be reasonably refused if disclosure would contravene applicable law. What if we added something in this section 4.2, such that disclosure may be reasonably refused if a subpoena or a court order is required to obtain the requested information? From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Lindsay Hamilton-Reid Sent: Thursday, March 8, 2018 10:00 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Hi Amy Thank you for the suggestion and while we have reworded another clause to compensate for the first part of your deletion, the part about court orders must remain. We will not provide information without a court order and will certainly not contravene applicable law. I know we are trying to find the right balance here but it must be reasonable. We will of course do what we can to help law enforcement but we are not here for the benefit of LEAs and do have the rights of our customers to protect, particularly in view of the GDPR and the upcoming ePrivacy regulations. Many thanks Lindsay Lindsay Hamilton-Reid Senior Legal Counsel Direct: +44 (0)1452 509145 | Mobile: 07720 091147 | Email: Lindsay.Hamilton-Reid(a)1and1.co.uk<mailto:Lindsay.Hamilton-Reid@1and1.co.uk> www.fasthosts.co.uk<http://www.fasthosts.co.uk/> www.1and1.co.uk<http://www.1and1.co.uk/> [fh-1and1] © 2015 All rights reserved. Fasthosts is the trading name of Fasthosts Internet Limited. Company registration no. 03656438. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 720821857. 1&1 is the trading name of 1&1 Internet Limited. Company registration no. 03953678. Registered in England and Wales. Registered office: Discovery House, 154 Southgate Street, Gloucester, GL1 2EX. VAT no. 752539027. This message (including any attachments) is confidential and may be legally privileged. If you are not the intended recipient, you should not disclose, copy or use any part of it - please delete all copies immediately and notify 1&1 on 0844 335 1211 or Fasthosts on 0333 0142 700. Any statements, opinions or information in this message are provided by the author, not on behalf of 1&1 and/or Fasthosts, unless subsequently confirmed by an individual who is authorised to represent 1&1 and/or Fasthosts. [linkedin]<http://www.linkedin.com/company/fasthosts-internet-ltd>[twitter]<https://twitter.com/Fasthosts>[facebook]<https://www.facebook.com/fasthostsinternet>[gplus]<https://plus.google.com/u/0/b/107582097021398424605/+fasthosts/posts>[blog]<http://blogs.fasthosts.co.uk/>[youtube]<http://www.youtube.com/user/Fasthostsinternet> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: 08 March 2018 12:07 To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Thanks, Peter, for your input on this. I’m noticing that while you aren’t happy with the proposed one business day requirement, you didn’t say that it’s a definite non-starter, either. Perhaps there is some room for compromise. Sara and other registrars who supported Sara’s proposed language, how would you feel about trimming the proposal to account for the discussion on Tuesday about points that are already covered elsewhere in the framework? If we did that, it would look something like this (edit to Sara’s proposal in redline): 4.1.2 Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day., noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. As proposed below, we could also update 3.1 to make abundantly clear that this is a direct LEA contact to the provider’s designated LEA contact, which may be an email address, form, phone number, or any other means the provider has shared with LEA. There must be a way for LEA to obtain the designated contact via the website (even instructions to call the provider’s main number would seem to satisfy this request) but the contact itself does not have to be posted on the website. 3.1 Pre‐Request: Provider will establish and maintain a designated LEA Requestor point of contact for submitting disclosure requests. Provider shall publish on its website the designated contact (e.g. email address, telephone number, form) or other means for LEA to obtain designated LEA contact information). If the language looked like this, for compliance purposes we could use some additional clarity about what it means for a provider to “use its best efforts to action the request within one business day.” Sara and other registrars who support this proposal, if we kept the “one business day” standard, would you be able to compromise by editing this a bit to make clear that a human (non-automated) response would be required within one business day of receipt of the request (perhaps by simply reverting to the word “action” if we were to clearly define that as discussed previously)? Peter, what would you and your PSWG colleagues think about this? Thanks, all for your continued attention to this matter. Hopefully, we can reach a conclusion on this while many of you are at ICANN61 in Puerto Rico. I’ll note that the poll is still open through EOD Friday, https://www.surveymonkey.com/r/CMGF8FZ. As of now, there are 18 responses. Four IRT members support raising this issue to the Council, and 14 oppose that (including some registrars). Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Roman, Peter (CRM) Sent: Wednesday, March 7, 2018 1:08 PM To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Action items from today's IRT call FWIW, I am not very happy with the one business day requirement to action the law enforcement High Priority request. Even a 24 hour window is too long. This is an emergency, that’s why we will be using this process. It really should be actioned more or less immediately. If it didn’t need immediate attention, we wouldn’t be using the High Priority process. Peter Roman Senior Counsel Computer Crime & Intellectual Property Section Criminal Division Department of Justice 1301 New York Ave., NW Washington, DC 20530 (202) 305-1323 peter.roman(a)usdoj.gov<mailto:peter.roman@usdoj.gov> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, March 6, 2018 11:42 AM To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Action items from today's IRT call Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. If you couldn’t attend, I encourage you to listen to the recording, https://community.icann.org/display/IRT/06+March+2018 If you haven’t already, please complete the IRT poll regarding the potential policy implications surrounding the IRT discussions on the LEA framework specification no later than Friday, https://www.surveymonkey.com/r/CMGF8FZ Currently, two IRT members have indicated that they believe the issue should be escalated to the Council. Fourteen responded that this should not be escalated to the Council at this stage. Today, we solicited any additional feedback related to the draft reporting specification. I’ve attached a draft with some notes indicating the feedback received to date. We will begin updating the specification based on this feedback, and will consider any additional feedback received between now and the end of the IRT session at ICANN61 in updating the draft. We also discussed a proposal from Sara Bockey on-list, which has been supported by several other registrar members of the IRT, for alternative language for the LEA Framework Specification. The proposed language is: 4.1.2 Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours. The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority. Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Based on the discussion today, it’s possible that an edit could potentially be made in Section 3.1, to eliminate the perceived need for the “contact the Provider directly” language, such as: 3.1 Pre‐Request: Provider will establish and maintain a designated LEA Requestor point of contact for submitting disclosure requests. Provider shall publish on its website the designated contact (e.g. email address, telephone number, form) or other means for LEA to obtain designated LEA contact information). I’ll note that because LEA are not a party to this contract, I don’t think they could be required via this contract to “make every effort,” so that may be a point to consider. Also, the draft already states, at Section 4.2.2.2 that a Provider can refuse disclosure if the disclosure would lead to a contravention of applicable law. Concerns have also been raised about the “best efforts” language. IRT feedback is requested on-list on the above proposed language. If IRT members who oppose the current PSWG-proposed text can reach agreement on proposed language, this can be published for public comment. This will be on the agenda for the session on Sunday at ICANN61. A full agenda will be distributed later this week. In addition, if the IRT would like to discuss any items from the updated PPAA draft in Puerto Rico, please let me know. 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>

10 24

Privacy/Proxy IRT Working Meeting at ICANN61
by Amy Bivins March 9, 2018

March 9, 2018

Dear Colleagues, Below, you will find our agenda and dial-in information for Sunday's face-to-face Privacy/Proxy IRT meeting at ICANN61, scheduled for 18:30-19:30 local time. For those that cannot attend, an update will be distributed to the group after the meeting, and the recording will be posted. Agenda: * Update on Project Status and Timeline * Finance Presentation * Outstanding Issues * LEA Framework Specification * Pending Updates to Reporting Specification, Per IRT Feedback * IRT Discussion Question Re: Data Escrow Specification (IRT views solicited about making Escrow Specification a Separate Document from PPAA (as is done in RAA), per question in circulated PPAA draft, to make it easier to update if/when technical requirements evolve) * Any IRT Feedback on Updated PPAA Draft * AOB Adobe Connect: https://participate.icann.org/sju61-208a If you haven't completed the poll requested by Darcy Southwell, as GNSO Council Liaison, related to the LEA Framework Specification, please complete it no later than your end of day today, https://www.surveymonkey.com/r/CMGF8FZ. As of now, 18 IRT members have completed the poll. Four support taking the LEA Framework Specification issue to the Council at this stage, and 14 oppose this course of action. Please let me know if you have any questions or concerns or specific items you would like to add to the agenda.

1 0

Action items from today's IRT call
by Amy Bivins March 8, 2018

March 8, 2018

Dear Colleagues, Thank you for your participation on today’s privacy/proxy IRT call. If you couldn’t attend, I encourage you to listen to the recording, https://community.icann.org/display/IRT/06+March+2018 If you haven’t already, please complete the IRT poll regarding the potential policy implications surrounding the IRT discussions on the LEA framework specification no later than Friday, https://www.surveymonkey.com/r/CMGF8FZ Currently, two IRT members have indicated that they believe the issue should be escalated to the Council. Fourteen responded that this should not be escalated to the Council at this stage. Today, we solicited any additional feedback related to the draft reporting specification. I’ve attached a draft with some notes indicating the feedback received to date. We will begin updating the specification based on this feedback, and will consider any additional feedback received between now and the end of the IRT session at ICANN61 in updating the draft. We also discussed a proposal from Sara Bockey on-list, which has been supported by several other registrar members of the IRT, for alternative language for the LEA Framework Specification. The proposed language is: 4.1.2 Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours. The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority. Where a disclosure request has been categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within one business day, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. Based on the discussion today, it’s possible that an edit could potentially be made in Section 3.1, to eliminate the perceived need for the “contact the Provider directly” language, such as: 3.1 Pre‐Request: Provider will establish and maintain a designated LEA Requestor point of contact for submitting disclosure requests. Provider shall publish on its website the designated contact (e.g. email address, telephone number, form) or other means for LEA to obtain designated LEA contact information). I’ll note that because LEA are not a party to this contract, I don’t think they could be required via this contract to “make every effort,” so that may be a point to consider. Also, the draft already states, at Section 4.2.2.2 that a Provider can refuse disclosure if the disclosure would lead to a contravention of applicable law. Concerns have also been raised about the “best efforts” language. IRT feedback is requested on-list on the above proposed language. If IRT members who oppose the current PSWG-proposed text can reach agreement on proposed language, this can be published for public comment. This will be on the agenda for the session on Sunday at ICANN61. A full agenda will be distributed later this week. In addition, if the IRT would like to discuss any items from the updated PPAA draft in Puerto Rico, please let me know. 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] Finance update re. today's PP IRT call
by Michele Neylon - Blacknight March 6, 2018

March 6, 2018

I’m attending Puerto Rico in person, but I sincerely doubt I’ll be attending that meeting in person, as I’ve a strong aversion to doing 12 hour days 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 <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of Chris Pelling <chris(a)netearth.net> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday 6 March 2018 at 12:40 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call Hi Jenn, Can you please confirm that the slides and their "reasoning" is sent out via this list please - as I am not attending in person, nor remotely as thats gone midnight UK time. Kind regards, Chris ________________________________ From: "Jennifer Gore" <jennifer.gore(a)icann.org> To: gdd-gnso-ppsai-impl(a)icann.org Sent: Tuesday, 6 March, 2018 12:28:37 Subject: [Gdd-gnso-ppsai-impl] Finance update re. today's PP IRT call Dear Colleagues, Unfortunately, the finance team will not be available to join our meeting today to present the data associated with the PP program fee schedule. However, they have committed to present in person during the IRT mtg in Puerto Rico on Sunday March 11, 2018 at 6:30 PM. If the meantime, please let me know if you have any questions. Thank you, Jennifer Gore _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

1 0

Summary, action items from today's PP IRT call
by Amy Bivins March 6, 2018

March 6, 2018

Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. We covered a lot of ground. If you could not attend, I encourage you to listen to the recording, available on the wiki, https://participate.icann.org/p39onhjd1g1/. Please review the items discussed today (summarized below) and provide any additional input to the list no later than your EOD Friday, 23 Feb. Monthly Reporting Specification 1. Issue 1: Report frequency-IRT members seemed to support a requirement that these reports be submitted quarterly (current draft suggested monthly). Absent contrary input on the list this week, this change will be made in next draft. 2. Issue 2: Report submission-on-list, some IRT members said that using ICANN reporting interface was too complicated and/or unnecessary. No one commented on this topic during today's meeting. Absent substantial input on this topic on-list this week indicating that many IRT members would support a contrary reporting mechanism, no changes will be made on this point. 3. Issue 3: Report format-on-list, some IRT members took issue with requiring both per-registrar and per-TLD reports. During the call, some IRT members indicating per-TLD could be too labor intensive, but other IRT members supported having per-TLD reports. Additional IRT input is requested on this point. 4. Issue 4: Report fields-on-list, suggestions have been made for eliminating some fields, and adding others. Based on the discussion in today's call (absent contrary and/or additional suggestions on-list) the specification will be updated to: eliminate "total" numbers for requests for specific contacts, eliminate "publication" fields for LEA and IP requests, add publication/disclosure-other fields to capture non-LEA/IP requests, add coded "reasons for denial" fields. PP Applicant Guide 1. Issue 1: Shift to "rolling" application period (eliminating application phases). IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 2. Issue 2: Elimination of many "essay" questions in favor of "checkbox" questions. IRT members supported this approach. Absent contrary feedback on-list we will proceed with this approach. 3. Issue 3: Fees proposal. IRT requested additional documentation of costs to support fees proposal (ICANN org will work to provide this ASAP). LEA Disclosure Framework Specification 1. Issue 1: Language re: notices to customers in Sections 6.3 and 4.3, while not directly contradictory, sets different standards for the timing of notice to customers regarding an LEA request. Per IRT input on-list and on today's call, edits will be made to make clear that Section 4.3 controls, and language to 4.3 to make clear that provide will notify customer of a request in accordance with ToS and timeframe requested by LEA, subject to any other requirements under applicable law or court order. Any additional input on this is requested by the end of the week. 2. Issue 2: Required provider responses to high priority LEA requests. Per discussion on-list and during today's call, it appears that * If "action" is clearly defined to include (1) disclosure of the requested information, (2) refusal to disclose the requested information for one of the reasons listed in section 4.2.2, and/or (3) in exceptional circumstances, informing LEA that the provider requires additional time to respond, then * The IRT appears to find a 24-hour response time acceptable for high-priority requests from LEA that qualify for this specification. * IRT feedback is specifically requested on this point. Please respond to the list noting whether you (1) support, (2) oppose, or (3) would edit (explain how) the requirement that providers be required to action high-priority requests from LEA within 24 hours of receipt of the request from LEA. If there is disagreement on this, this will be flagged during the public comment period. 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>

15 34

IRT Member Poll, Please Complete by EOD Friday, 9 March
by Amy Bivins March 5, 2018

March 5, 2018

Dear Colleagues, Pursuant to Darcy's request sent to the list on Friday, please complete this linked poll, which will be used to gauge IRT consensus with respect to any potential policy implications raised by the current IRT debate on the draft LEA framework specification, https://www.surveymonkey.com/r/CMGF8FZ. Please complete this poll no later than your end of day Friday, 9 March. I've also included a couple of questions related to the reporting specification, to ensure we collect as many IRT member views on this topic as possible. For our meeting tomorrow, we will have a presentation from the Finance team with more information about the proposed program fees schedule. We can also discuss any issues you would like to raise related to the updated PPAA draft that was distributed last week and the proposed agenda for the IRT meeting at ICANN61. If you have specific you would like to discuss, please send them to the list before the call if possible. 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>

6 7

Updated PPAA draft and related materials attached for IRT review
by Amy Bivins March 3, 2018

March 3, 2018

Dear Colleagues, Attached is the updated PPAA draft, in redline and non-redline versions. I've also included a version with references to the Final report and notes to the IRT about where edits were made (or not made). The attached slide deck includes an overview of the accreditation program materials, remaining open issues, and identifies how each of the Final Recommendations are proposed to be implemented. Please begin reviewing the updates to the PPAA draft and come prepared to discuss at our meeting on Tuesday. Also, please provide any final feedback on the LEA framework and reporting specification no later than this Friday, 2 March. We plan to update this draft with respect to feedback received on those issues next week as we prepare these materials for the public comment period. Brief, high-level summary of the changes/questions for the IRT in this PPAA draft: 1. Non-substantive copy edits throughout 2. Labeling specification (and all references to this specification) deleted based on IRT feedback that the requirements therein appeared to be beyond scope. Labeling requirement included in PPAA body at Section 3.15. 3. Reporting specification (and references to this specification) added. Specification remains under IRT review (deadline for feedback 2 March). Links to PP IETF documents are not yet functional, as these are not yet published. These are expected to be published prior to the publication of the draft PPAA for public comment and links will be updated if needed when this specification is finalized based on final IRT feedback. 4. Definition of "Working Group" (applicable to amendment, negotiation processes-See, e.g., Section 7.4.1) updated throughout PPAA to eliminate references to any future PPSG. In its place, the WG will now be convened by the GNSO Council (See PPAA Section 1.43), as recommended by the IRT. 5. All references to a Provider terminating a customer's domain registration or requesting that a registrar do so in response to a breach of the terms of service or other wrongs have been deleted, per IRT input. (See, e.g. Section 3.5.3.1; See, specifically, Section 3.5.3.17 (regarding cancellations of services related to names that are subject to UDRP/URS proceedings.) 6. Explicit requirement that Provider publish its terms of service has been added (See Section 3.8.1). Prior draft referenced requirements for ToS contents but didn't explicitly require that ToS be published, as directed by the Final Report. 7. Abuse desk requirement in PPAA Section 3.12.1 edited to match language in Final Report (language about the abuse contact being "capable and authorized to investigate..." from the Final Report had been inadvertently deleted at some point in a prior draft). 8. Deletion of LEA-related abuse contact requirements in PPAA text (formerly section 3.12.2). All LEA-specific requirements are now included in the LEA Disclosure Framework Specification. 9. Reference to use of "high-volume, automated electronic processes..." in PPAA section 3.14 was moved to Intellectual Property Disclosure Framework Specification. 10. Clarification added that a provider on suspended status may continue to provide services for existing registrations (Section 5.7.3) 11. Several clean-up edits in Specification 1, Data Escrow Specification. ICANN is currently reviewing the inclusion of this Specification in the PPAA itself, as opposed to the RAA format which has the escrow specification separate from the accreditation agreement. As technical requirements/RFCs may be updated from time to time, there are benefits to having this outside the PPAA itself. IRT feedback is requested on this topic. 12. Specification 2: Customer Data Accuracy Program Specification. Edit to Section 1, to clarify that obligation applies when Provider begins providing the Services for a name, as opposed to when the name is registered. 13. Specification 4: Law Enforcement Authority Specification. This specification is currently under final IRT review (deadline for feedback 2 March). Substantive edits may be made after this review period. There is currently some disagreement among IRT members regarding high priority requests, specifically: (a) how the receipt process should or should not apply to high priority requests, (b) the time that should be allowed for a provider to action a "high priority" request. In addition, the IRT is considering defining "action" for greater clarity. 14. Data retention specification: The data required to be retained has been reduced by the deletion of the labeling specification (see Section 1.1.6). 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>

6 8

Reminder: No IRT meeting today
by Amy Bivins Feb. 27, 2018

Feb. 27, 2018

Dear Colleagues, This is a reminder that we do not have an IRT meeting today. Please send any further input you have on the topics discussed last week to the list by your end of day Friday. We are finalizing the PPAA draft (minus the remaining items that are open on the list) and I hope to be able to send it to you by this evening or tomorrow morning. Amy Sent from my iPhone

5 5

Agenda, materials for Tuesday's PP IRT call
by Amy Bivins Feb. 20, 2018

Feb. 20, 2018

Hello, All, At our next PP IRT meeting, we will discuss the following: * LEA Framework Specification: * Remaining issue re: time period for actioning high priority requests. If no agreement is reached this will be flagged for the public comment period. We will discuss most recent suggestions made on the list and determine whether there is an IRT consensus to adopt any of these proposed changes. * Question from ICANN about Section 6.3's application to Section 4.3: Do you view these sections to be in conflict? * Section 6.3 states that Customer Notification should take place at the earliest opportunity, unless such disclosure would pose a risk to operational sensitivity; safety of individuals; or is prohibited by law or court order. Such circumstances must be detailed in the disclosure request. * Text of 6.3 was included in PSWG's initial proposal. * Section 4.3 (in summary, also included in PSWG initial proposal) states that the provider will notify the customer of a disclosure request in accordance with its terms of service and the timeframe identified by LEA. The provider may voluntarily set a generic timeframe for this notice, such as 90 days, which can be extended at LEA's request. * IRT feedback on draft Monthly Reporting Specification, distributed earlier this week (also attached) * IRT feedback on updated draft Applicant Guide (attached). Please note that the proposed application process has been substantially updated since the IRT's last review of this document, and that the proposed fee schedule has been updated. Please review these items prior to our meeting and come prepared to discuss each of these topics. 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>

6 5

PPAA Reporting Specification Attached for IRT review
by Amy Bivins Feb. 16, 2018

Feb. 16, 2018

Dear Colleagues, A new draft PPAA specification, the monthly reporting specification, is ready for your review. This specification includes the requirements for provider reports to ICANN. This specification is proposed to implement the recommendation from the Final Report, "providers should be required to maintain statistics on the number of Publication and Disclosure requests received and the number honored, and provide these statistics in aggregate form to ICANN for periodic publication. The data should be aggregated so as not to create a market where nefarious users of the domain name system are able to use the information to find the P/P service that is least likely to make Disclosures." (See Final Report, p. 18). We can discuss this during our call next week if you have any questions or comments. I'll also be sending the updated Applicant Guide to the list later this week, for discussion on Tuesday. Looking ahead, we are working to finalize the RRI Specification that accompanies the attached reporting specification. The RRI Specification will include the technical specifics for submitting these reports via the API. I'll send it to the list as soon as it is available. We are also in the process of reviewing the Labeling Specification, pursuant to IRT feedback, and will have an updated draft for the IRT to review as soon as possible. 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>

5 14

Notes, Action Items From Today's PP IRT Call
by Amy Bivins Feb. 16, 2018

Feb. 16, 2018

Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. For those who could not attend, I encourage you to review the recording, which is posted on the wiki, https://community.icann.org/display/IRT/13+February+2018. Today, we discussed three topics: (1) the updated de-accreditation procedure; (2) the updated Policy document; and (3) the ongoing discussion on the list re: the LEA framework specification, specifically the processes of discussing the disagreement about the timing of a provider's "actioning" of a "high priority" request. Please review the attached materials, summary below and/or the recording and provide any further input on these topics by the end of this week. IRT feedback is specifically requested on the five recommendations received from IRT members related to the LEA Framework Specification. This will be discussed next week. IRT Input on De-Accreditation Process * Recommendation 1: In Section 2.2.4, edit to note that this right of transfer is subject to the ICANN transfer policy. * Proposed response: This edit will be made unless we receive input to the contrary that warrants further discussion. * Recommendation 2: In Section 2.5, delete references to specific methods of contact. * Proposed response: This edit will be made unless we receive input to the contrary that warrants further discussion. * Recommendation 3: In Section 3, should there be more specifics about what this notice should require? Section 2.4 could be referenced, for example. * Proposed response: Absent further input on Section 2.4, a reference to Section 2.4 will be added. IRT Input on Draft Policy Document * Recommendation 1: Eliminate use of "Person" in definitions. * Proposed response 1: This topic has been raised before, but did not appear to have widespread support by members of the IRT. The word "Person" was used to ensure consistency across definitions and for clarity and conciseness. As a result, it seems preferable to retain the use of the word "Person," absent feedback that indicates it is the consensus view of the IRT to eliminate the use of the word "Person." * Proposed response 2: One IRT member suggested that the word "Person" could be added to the definitions section of this document for added clarity. This edit will be made unless we receive input to the contrary that warrants further discussion. * Recommendation 2: Implementation of RDDS requirements, as a matter of policy, should be done through high-level WHOIS policy rather than piecemeal in this Policy document, as this could be lost over time as/when/if other WHOIS requirements are updated. * Proposed response: Additional IRT feedback is requested on this topic, and staff will also consult about this topic. There are many different ICANN policies that concern WHOIS/RDDS (https://www.icann.org/resources/pages/registrars/consensus-policies-en) The CL&D Policy does specifically concern labeling, which is what the requirement here is about, https://www.icann.org/resources/pages/rdds-labeling-policy-2017-02-01-en. LEA Framework Discussions The IRT has been discussing the draft LEA Disclosure Framework Specification periodically for approximately nine months. Most elements of this draft framework appear to be settled, but disagreement remains on one specific point: how and when a provider must "action" a "high priority" request. PSWG members of the IRT have proposed that high priority requests be actioned within 24 hours. IRT members, particularly registrars, contend that this time period is unreasonable. The most recent feedback received on this on the list for proposed edits to the current draft (which currently requires that a high priority request be actioned within 24 hours) is as follows: * Recommendation 1: Where a disclosure request has been categorized as High Priority, Provider shall use its best efforts towards actioning the request within 24 hours on business days or as close as possible to this, or "actioning the request within 24 hours for up to 90% (or some other level determined acceptable by Providers) of incidences." * Recommendation 2: Add "without limitations" back to section 4.2.2. What's listed under 4.2.2 should be non-limiting examples for when disclosure can be reasonably refused. * Recommendation 3: Define the word "Action" as follows (or similar): "As used in this subsection, "action" means (i) to disclose to the LEA requestor, or (ii) to refuse to disclose to the LEA requestor, citing one or more of the reasons listed in 4.2.2"?; or to add, after "action," "in accordance with subsection 4.2," which includes both the options listed (as well as the option of extending the deadline, "in exceptional circumstances," see 4.2.4). * Recommendation 4: Where a disclosure request is categorized as High Priority, LEA will make every effort to contact the Provider directly to discuss the matter, and should it be determined that Provider has useful information, Provider shall use its best efforts to action the request within 24 hours, noting that a court order/subpoena may still be required prior to release of any information. Registrar will not be required to take any action in contravention of applicable law. * Recommendation 5: Edit to state that "Provider shall use reasonable efforts to respond to the request as soon as possible" as opposed to Provider shall use its best efforts to action the request within 24 hours. IRT Action Item: IRT feedback is specifically requested on these five recommendations. This will be discussed once more, on Tuesday, with the goal of determining whether agreement can be reached or not on any further changes to the current draft. If agreement cannot be reached on Tuesday, the various positions will be specifically noted in the call for public comments. 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] Request for IRT Feedback: LEA Framework Specification, Receipt Process's Application to High Priority Requests
by Sara Bockey Feb. 13, 2018

Feb. 13, 2018

A few items. Again, I’m concerned that we are creating policy, not implementing it. Granted, the framework outlined in the Final Report is not as robust as what is detailed for IPC, but then again LEA did not participate in the PDP process. The IRT is not the place to be creating policy for LEAs. That said, the problem with a strict 24-hour period is that it doesn’t acknowledge certain situations/matters may require additional time, falling outside a 24-hour period despite a Provider’s best efforts. Language such as “Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours” are overly strict and sets the Provider up for failure/being out of compliance due to circumstances beyond its control. Finally, I fear the LEA framework as currently written creates unrealistic expectations/SLAs. There seems to be a presumption of disclosure – if LEAs check all the right boxes, the information will be disclosed. However, this decision should reside with the provider, who does not have to bypass due process just to please LEAs. 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: Monday, February 5, 2018 at 7:51 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Request for IRT Feedback: LEA Framework Specification, Receipt Process's Application to High Priority Requests Dear Colleagues, As mentioned on the list a couple of weeks ago, the current draft PPAA is still a bit ambiguous regarding how the review process outlined in Section 3.2.1 applies to high priority requests. We need ensure that the draft is clear about this requirement when we go out for public comment (and if there is opposition to the proposed requirement by any members of the IRT, this will be flagged in the call for comments). Upon reviewing the IRT’s input to date, I am proposing an edit that I believe reflects the IRT discussion on this point. Please review and provide your comments on this proposed language no later than this Friday, 9 February. To summarize, the current draft contains a two-step process for Providers upon receipt of a request from LEA. (1) Within two business days, the Provider must review the request and confirm to the LEA requester that it has been received and contains the relevant information required to meet the minimum standard for acceptance (See 3.2.1 of Specification 4). (2) The Provider must then action the request in accordance with the priority level (within 24 hours for “high priority” requests (4.1.2); or within the timeline requested by LEA, if possible, for other requests (See 4.1.3). The current language may be a bit ambiguous as to whether the two business day “review period” applies before the 24-hour period for responding to high priority requests (as explained in more detail in the attached message). The view of registrar IRT members appears to be that requiring action within 24 hours of receipt of an LEA request, even if it is a high priority request, is unacceptable. PSWG members of the IRT disagree. Other IRT members appear to have mixed views on this (some referenced the RAA requirement that “Well-founded reports of Illegal Activity submitted to these [dedicated LEA] contacts must be reviewed within 24 hours by an individual who is empowered by Registrar to take necessary and appropriate actions in response to the report.” Registrar members of the IRT said that the RAA-required review is less intensive than the PPAA review due to the specific requirements in the PPAA draft). Based on the views expressed within the IRT, it appears that one potential solution to this ambiguity would be to update Section 4.1.2 to state that (proposed edit in red), “Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours of completion of the receipt process outlined in Section 3.2.” The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority.” The practical impact of this proposed change would be that the provider must action a high priority request within 24 hours of determining that the request meets the minimum standard for acceptance. If the provider completes the receipt process sooner than 2 business days after receipt of the request, this would start the 24-hour clock for actioning the request. Thus, this could shorten the response window a bit, partially addressing the PSWG concerns of a “two business days plus 24 hours” requirement, while also addressing registrar concerns by not starting the clock until the provider has time to review the request, if the full time of the receipt process is required to conduct that review. Please provide your feedback on this proposed change no later than this Friday, 9 Feb. And if you have further comments on this, please share those as well. 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 tomorrow's PP IRT call
by Michelle DeSmyter Feb. 12, 2018

Feb. 12, 2018

Hi Chris, Thank you for this, I will note your apology for tomorrow's meeting. Kind regards, Michelle From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Chris Pelling <chris(a)netearth.net<mailto:chris@netearth.net>> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Monday, February 12, 2018 at 12:32 PM To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for tomorrow's PP IRT call Hi Amy, Sorry I wont be able to make this tomorrow. Kind regards, Chris ________________________________ From: "Amy Bivins" <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Sent: Monday, 12 February, 2018 17:23:47 Subject: [Gdd-gnso-ppsai-impl] Materials for tomorrow's PP IRT call Hello, All, In advance of tomorrow's IRT call, I'm attaching the updated PP Policy document (in both clean and redline versions) and the de-accreditation process document in redline. Tomorrow we're planning to walk through the updates to these documents since we've last discussed them, and then we'll leave them open for your feedback. Following up on the discussion on the list this past week, we've seen significant discussion of the LEA disclosure framework. I don't believe that Peter is available tomorrow to join us, so we should wait until he is available (hopefully next week) to discuss. If, despite the progression of this discussion, we are unable to reach agreement on the topic, we will flag the various suggestions and views raised by IRT members for public comment. 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> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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Materials for tomorrow's PP IRT call
by Amy Bivins Feb. 12, 2018

Feb. 12, 2018

Hello, All, In advance of tomorrow's IRT call, I'm attaching the updated PP Policy document (in both clean and redline versions) and the de-accreditation process document in redline. Tomorrow we're planning to walk through the updates to these documents since we've last discussed them, and then we'll leave them open for your feedback. Following up on the discussion on the list this past week, we've seen significant discussion of the LEA disclosure framework. I don't believe that Peter is available tomorrow to join us, so we should wait until he is available (hopefully next week) to discuss. If, despite the progression of this discussion, we are unable to reach agreement on the topic, we will flag the various suggestions and views raised by IRT members for public comment. 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 tomorrow's PP IRT call
by Darcy Southwell Feb. 12, 2018

Feb. 12, 2018

My apologies, but I won’t be able to make tomorrow’s meeting. I will follow up by listening to the recording. Darcy 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> Date: Monday, February 12, 2018 at 9:23 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials for tomorrow's PP IRT call Hello, All, In advance of tomorrow’s IRT call, I’m attaching the updated PP Policy document (in both clean and redline versions) and the de-accreditation process document in redline. Tomorrow we’re planning to walk through the updates to these documents since we’ve last discussed them, and then we’ll leave them open for your feedback. Following up on the discussion on the list this past week, we’ve seen significant discussion of the LEA disclosure framework. I don’t believe that Peter is available tomorrow to join us, so we should wait until he is available (hopefully next week) to discuss. If, despite the progression of this discussion, we are unable to reach agreement on the topic, we will flag the various suggestions and views raised by IRT members for public comment. 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 www.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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Doc's for 2/13 PPSAI IRT call?
by Metalitz, Steven Feb. 12, 2018

Feb. 12, 2018

Hello Amy, In the run up to tomorrow's call I am checking on the status of the 2 documents you referenced in the message below as likely to be ready for review by the IRT by then: (1) One additional specification to review, related to the proposed format for monthly reporting (2) Updates to the draft Policy document, de-accreditation process document, and Applicant Guide based on the IRT's input Thanks in advance for the latest on this. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, January 30, 2018 11:14 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Action items, next steps following today's IRT call Dear Colleagues, Thank you for your participation on today's privacy/proxy IRT call. If you couldn't attend, I encourage you to listen to the (very short) recording, available on the wiki, https://community.icann.org/display/IRT/30+January+2018<https://community.icann.org/display/IRT/30+January+2018> Today, we reviewed proposed edits to Specification 5, including the addition of the following text from the Final Report to the specification's introduction (see p. 85 of the Final Report), "Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy." Barring any further IRT discussion on this change, or the other following typographical changes throughout the specification, we will make these edits to the next PPAA draft: * Updating references to "WHOIS" to "RDDS" throughout the specification; * Updating the word "Policy" to "Specification" throughout the specification; * Changing the word "trademark" to "copyright" in Section 32.2.7.4<http://32.2.7.4>. We also reviewed the previously agreed-upon plan to publish the draft data retention specification as-is, with the understanding that this could be impacted at a later date by the parallel GDPR work that is currently underway. Please send any further input you have on these items to the list this week. Next Steps We have one additional specification to review, related to the proposed format for monthly reporting (we expect this will mostly be of interest to the registrar members of the IRT). If this is ready next week we will review but, if not, we may cancel next week's meeting. I'll let you know by the end of this week. Meanwhile, ICANN Org is finalizing updates to the draft Policy document, de-accreditation process document, and Applicant Guide based on the IRT's input. I expect to be able to share these with you next week, for discussion the following week (the week of 13 February). I hope to be able to share the next PPAA draft with you the week of 13 Feb, for final IRT review over the following couple of weeks. Once these materials have been reviewed by the IRT, we will be ready for public comment. Our hope is to publish these for comment by the end of February, or at least prior to ICANN61. We have requested an IRT meeting slot for ICANN61, but do not have a date/time confirmed yet. Provided we are out for comment at that point, we plan to discuss the remaining Transfer Policy issue during that meeting. 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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Request for IRT Feedback: LEA Framework Specification, Receipt Process's Application to High Priority Requests
by Amy Bivins Feb. 5, 2018

Feb. 5, 2018

Dear Colleagues, As mentioned on the list a couple of weeks ago, the current draft PPAA is still a bit ambiguous regarding how the review process outlined in Section 3.2.1 applies to high priority requests. We need ensure that the draft is clear about this requirement when we go out for public comment (and if there is opposition to the proposed requirement by any members of the IRT, this will be flagged in the call for comments). Upon reviewing the IRT's input to date, I am proposing an edit that I believe reflects the IRT discussion on this point. Please review and provide your comments on this proposed language no later than this Friday, 9 February. To summarize, the current draft contains a two-step process for Providers upon receipt of a request from LEA. (1) Within two business days, the Provider must review the request and confirm to the LEA requester that it has been received and contains the relevant information required to meet the minimum standard for acceptance (See 3.2.1 of Specification 4). (2) The Provider must then action the request in accordance with the priority level (within 24 hours for "high priority" requests (4.1.2); or within the timeline requested by LEA, if possible, for other requests (See 4.1.3). The current language may be a bit ambiguous as to whether the two business day "review period" applies before the 24-hour period for responding to high priority requests (as explained in more detail in the attached message). The view of registrar IRT members appears to be that requiring action within 24 hours of receipt of an LEA request, even if it is a high priority request, is unacceptable. PSWG members of the IRT disagree. Other IRT members appear to have mixed views on this (some referenced the RAA requirement that "Well-founded reports of Illegal Activity submitted to these [dedicated LEA] contacts must be reviewed within 24 hours by an individual who is empowered by Registrar to take necessary and appropriate actions in response to the report." Registrar members of the IRT said that the RAA-required review is less intensive than the PPAA review due to the specific requirements in the PPAA draft). Based on the views expressed within the IRT, it appears that one potential solution to this ambiguity would be to update Section 4.1.2 to state that (proposed edit in red), "Where a disclosure request has been categorized as High Priority, this must be actioned within 24 hours of completion of the receipt process outlined in Section 3.2." The LEA Requestor will detail the threat type and justification for a request with a Priority Level of High Priority." The practical impact of this proposed change would be that the provider must action a high priority request within 24 hours of determining that the request meets the minimum standard for acceptance. If the provider completes the receipt process sooner than 2 business days after receipt of the request, this would start the 24-hour clock for actioning the request. Thus, this could shorten the response window a bit, partially addressing the PSWG concerns of a "two business days plus 24 hours" requirement, while also addressing registrar concerns by not starting the clock until the provider has time to review the request, if the full time of the receipt process is required to conduct that review. Please provide your feedback on this proposed change no later than this Friday, 9 Feb. And if you have further comments on this, please share those as well. 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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Canceled--PP IRT meeting scheduled for 6 Feb
by Amy Bivins Feb. 2, 2018

Feb. 2, 2018

Dear Colleagues, The Privacy/Proxy IRT meeting scheduled for 6 February has been canceled. We will reconvene the following week, 13 February. Please watch your inboxes, as updated materials should be distributed for your review and discussion on 13 February by the end of next week. Best (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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Action items, next steps following today's IRT call
by Amy Bivins Jan. 30, 2018

Jan. 30, 2018

Dear Colleagues, Thank you for your participation on today's privacy/proxy IRT call. If you couldn't attend, I encourage you to listen to the (very short) recording, available on the wiki, https://community.icann.org/display/IRT/30+January+2018 Today, we reviewed proposed edits to Specification 5, including the addition of the following text from the Final Report to the specification's introduction (see p. 85 of the Final Report), "Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy." Barring any further IRT discussion on this change, or the other following typographical changes throughout the specification, we will make these edits to the next PPAA draft: * Updating references to "WHOIS" to "RDDS" throughout the specification; * Updating the word "Policy" to "Specification" throughout the specification; * Changing the word "trademark" to "copyright" in Section 32.2.7.4. We also reviewed the previously agreed-upon plan to publish the draft data retention specification as-is, with the understanding that this could be impacted at a later date by the parallel GDPR work that is currently underway. Please send any further input you have on these items to the list this week. Next Steps We have one additional specification to review, related to the proposed format for monthly reporting (we expect this will mostly be of interest to the registrar members of the IRT). If this is ready next week we will review but, if not, we may cancel next week's meeting. I'll let you know by the end of this week. Meanwhile, ICANN Org is finalizing updates to the draft Policy document, de-accreditation process document, and Applicant Guide based on the IRT's input. I expect to be able to share these with you next week, for discussion the following week (the week of 13 February). I hope to be able to share the next PPAA draft with you the week of 13 Feb, for final IRT review over the following couple of weeks. Once these materials have been reviewed by the IRT, we will be ready for public comment. Our hope is to publish these for comment by the end of February, or at least prior to ICANN61. We have requested an IRT meeting slot for ICANN61, but do not have a date/time confirmed yet. Provided we are out for comment at that point, we plan to discuss the remaining Transfer Policy issue during that meeting. 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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Copy edits to Spec. 5
by Metalitz, Steven Jan. 29, 2018

Jan. 29, 2018

PPSAI IRT colleagues, In advance of our discussion tomorrow on Specification 5, the Intellectual Property Disclosure Framework Specification, I offer a handful of copy edits/typo corrections in the attached document. Mainly this involves substituting the word "Specification" for "Policy" and "RDDS" for "Whois." In case you have trouble distinguishing these copy edits from the ICANN staff's redlines, note that the only sections I have touched are the following: 1.3, 1.4, 2.2.2, 2.2.7.4, 2.3.2, 3.1.2.1. In addition, I suggest we find the appropriate place in this Specification for implementation of the following paragraph from the Illustrative Disclosure Framework adopted by the PDP Working Group: "Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy." Looking forward to our discussion tomorrow. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, January 23, 2018 2:53 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Final IRT Feedback Due EOD Sunday 28 Jan: draft LEA framework Dear Colleagues, Thanks so much for your active participation on today's Privacy/Proxy Accreditation Program IRT call. If you were unable to attend, I encourage you to listen to the recording. Today, we continued discussing the LEA disclosure framework specification in the draft PPAA (pp. 50-54 of the draft contract, attached). The discussion today confirmed that there is continued uncertainty regarding two items in the draft framework. Please submit any final feedback that you have on these topics to the list this week. After this final feedback period, if this issue/these issues are unresolved, they will be specifically identified as unresolved in the call for public comments. Section 3.1: As drafted, this section requires Providers to publish on their websites the designated LEA contact (e.g. email address, telephone number, form or other means for LEA to obtain the designated LEA contact information). Summary of Issue: Many members of the IRT support the deletion of the requirement that this contact (or a means to obtain this contact) appear on the Provider's website. The RAA does not require registrars to publish the registrar LEA contact on the registrar website (See RAA 3.18.2). There appear to be at least a few possible paths forward: 1. Keep language as-is. 2. Delete the second sentence of 3.1, which requires that this information be posted on the Provider website. 3. Replace the second sentence of 3.1 with language such as that suggested by Steve Metalitz, "Provider shall provide to LEA an appropriate means for LEA to obtain the designated LEA contact information." 4. Language from Section 3.18.2 of the RAA could be adapted for this agreement by changing "Registrar" to "Provider" or by making additional edits: 3.18.2 Registrar shall establish and maintain a dedicated abuse point of contact, including a dedicated email address and telephone number that is monitored 24 hours a day, seven days a week, to receive reports of Illegal Activity by law enforcement, consumer protection, quasi-governmental or other similar authorities designated from time to time by the national or territorial government of the jurisdiction in which the Registrar is established or maintains a physical office. 5. We could keep the language as-is for now, note any remaining disagreement about whether the contact (or a way to obtain it) should be posted on the Provider's website during the public comment period, and request community feedback on potential paths forward. 6. Some other path (please explain). Timeline for Providers to Action "High Priority" Requests From LEA Summary of Issue: The current PPAA draft contains a two-step process for Providers upon receipt of a request from LEA. (1) Within two business days, the Provider must review the request and confirm to the LEA requester that it has been received and contains the relevant information required to meet the minimum standard for acceptance (See 3.2.1). (2) The Provider must then action the request in accordance with the priority level (within 24 hours for "high priority" requests (4.1.2); or within the timeline requested by LEA, if possible, for other requests (See 4.1.3). Note 1: The RAA requires (See Section 3.18.2) that "Well-founded reports of Illegal Activity submitted to these [dedicated LEA] contacts must be reviewed within 24 hours by an individual who is empowered by Registrar to take necessary and appropriate actions in response to the report." Note 2: There is some uncertainty, as this is currently drafted, as to whether the 2 business day review period applies before the 24 hour response time for "high priority" requests. Section 4.1.1 states that "Upon completion of the Receipt Process Specified in Section 3 of this Specification, Provider will action, in accordance with Sections 4.2 and 4.3 of this Specification, the disclosure request in accordance with the Priority Level." Upon the resolution of the issue below, we will review the specification as a whole to ensure it reflects the intended result. IRT questions: 1. Should Providers be required to action all "high priority" requests within 24 hours of receipt, as recommended by PSWG (and not apply the 2 business day "receipt period" first)? 2. If no, do you see a compromise short of applying the current 2 business day receipt period prior to the 24-hour period for actioning a "high priority" request? Thanks so much for your continued input on these topics. Next week, we will pick up our discussion with the IP Disclosure Framework Specification. 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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Final IRT Feedback Due EOD Sunday 28 Jan: draft LEA framework
by Amy Bivins Jan. 24, 2018

Jan. 24, 2018

Dear Colleagues, Thanks so much for your active participation on today's Privacy/Proxy Accreditation Program IRT call. If you were unable to attend, I encourage you to listen to the recording. Today, we continued discussing the LEA disclosure framework specification in the draft PPAA (pp. 50-54 of the draft contract, attached). The discussion today confirmed that there is continued uncertainty regarding two items in the draft framework. Please submit any final feedback that you have on these topics to the list this week. After this final feedback period, if this issue/these issues are unresolved, they will be specifically identified as unresolved in the call for public comments. Section 3.1: As drafted, this section requires Providers to publish on their websites the designated LEA contact (e.g. email address, telephone number, form or other means for LEA to obtain the designated LEA contact information). Summary of Issue: Many members of the IRT support the deletion of the requirement that this contact (or a means to obtain this contact) appear on the Provider's website. The RAA does not require registrars to publish the registrar LEA contact on the registrar website (See RAA 3.18.2). There appear to be at least a few possible paths forward: 1. Keep language as-is. 2. Delete the second sentence of 3.1, which requires that this information be posted on the Provider website. 3. Replace the second sentence of 3.1 with language such as that suggested by Steve Metalitz, "Provider shall provide to LEA an appropriate means for LEA to obtain the designated LEA contact information." 4. Language from Section 3.18.2 of the RAA could be adapted for this agreement by changing "Registrar" to "Provider" or by making additional edits: 3.18.2 Registrar shall establish and maintain a dedicated abuse point of contact, including a dedicated email address and telephone number that is monitored 24 hours a day, seven days a week, to receive reports of Illegal Activity by law enforcement, consumer protection, quasi-governmental or other similar authorities designated from time to time by the national or territorial government of the jurisdiction in which the Registrar is established or maintains a physical office. 5. We could keep the language as-is for now, note any remaining disagreement about whether the contact (or a way to obtain it) should be posted on the Provider's website during the public comment period, and request community feedback on potential paths forward. 6. Some other path (please explain). Timeline for Providers to Action "High Priority" Requests From LEA Summary of Issue: The current PPAA draft contains a two-step process for Providers upon receipt of a request from LEA. (1) Within two business days, the Provider must review the request and confirm to the LEA requester that it has been received and contains the relevant information required to meet the minimum standard for acceptance (See 3.2.1). (2) The Provider must then action the request in accordance with the priority level (within 24 hours for "high priority" requests (4.1.2); or within the timeline requested by LEA, if possible, for other requests (See 4.1.3). Note 1: The RAA requires (See Section 3.18.2) that "Well-founded reports of Illegal Activity submitted to these [dedicated LEA] contacts must be reviewed within 24 hours by an individual who is empowered by Registrar to take necessary and appropriate actions in response to the report." Note 2: There is some uncertainty, as this is currently drafted, as to whether the 2 business day review period applies before the 24 hour response time for "high priority" requests. Section 4.1.1 states that "Upon completion of the Receipt Process Specified in Section 3 of this Specification, Provider will action, in accordance with Sections 4.2 and 4.3 of this Specification, the disclosure request in accordance with the Priority Level." Upon the resolution of the issue below, we will review the specification as a whole to ensure it reflects the intended result. IRT questions: 1. Should Providers be required to action all "high priority" requests within 24 hours of receipt, as recommended by PSWG (and not apply the 2 business day "receipt period" first)? 2. If no, do you see a compromise short of applying the current 2 business day receipt period prior to the 24-hour period for actioning a "high priority" request? Thanks so much for your continued input on these topics. Next week, we will pick up our discussion with the IP Disclosure Framework Specification. 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 PP IRT meeting
by Amy Bivins Jan. 22, 2018

Jan. 22, 2018

Hello, All, Thanks so much for your input on the list last week. Tomorrow, we will pick up where we left off last week, continuing to discuss the LEA disclosure framework specification. We will continue to discuss remaining IRT comments that we have received on the remainder of the specifications. I'm also attaching for your information the most recent data escrow specification, which is not included in the current PPAA draft, but will be included in the next version. This document was last discussed by the IRT in October, and we have received no recommendations for edits to it since then. Unless any additional IRT feedback on this reveals a need for changes, this will be included as-is in the next PPAA draft. 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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Summary of today's privacy/proxy IRT call, IRT action items
by Amy Bivins Jan. 18, 2018

Jan. 18, 2018

Dear Colleagues, Thanks so much for your active participation on today's privacy/proxy IRT call. If you were unable to attend, I encourage you to listen to the recording, which is available on the wiki, https://participate.icann.org/p8nkvqvkvyr/ Today we began reviewing the most recent round of IRT member comments on the PPAA specifications. Some high-level notes regarding our discussions are below. Please send any additional input you have on the topics discussed today to the list no later than the end of this week. Next week, we will pick up where we left off today on the LEA disclosure framework specification. Specification 1: Customer Data Accuracy Specification Issue 1: Re: IRT member comment-this specification needs to be revisited, confusing as to how this is impacted by Affiliate/TPP status Proposed Solution: Move Section 3 to the beginning of this specification. Issue 2: Should Section 1 be edited to add an additional trigger-when the privacy and/or proxy service is enabled? Rationale: PP Service could be turned on in response to a WHOIS accuracy complaint, resulting in the shielding of potentially inaccurate information instead of validation/verification. IRT Feedback on this proposal was mixed. Additional feedback is requested. Issue 3: In Section 5, IRT member recommended that all references to registrars to terminate or suspend should be removed. Rationale: Registrars are not bound by this contract. IRT Feedback: At a minimum, registrars should be notified if PP service is suspended or terminated due to inaccurate customer contact information. This will trigger registrar obligations under the RAA to validate/verify. Issue 4: In Section 6, does addition of "by Registrar" solve issue (to clarify that PP provider cannot place names on clientHold or TransferProhibited status)? IRT Feedback seemed to support this change. Specification 2: Registration Data Directory Service Labeling Specification Issue 1: Is this specification attempting to require retention of this data, or to simply identify what information should appear in WHOIS for PP registrations? Assuming the latter, this specification should be updated (perhaps in introductory language in Section 1, and potentially moving up section 3) to clearly note this purpose. In addition, labeling requirements for "registrant organization" field should be added as an example in Section 1. Sections 3.2.1 and 3.5.3 should also be reviewed to ensure consistency across contract text, data retention specification and this specification. Specification 3: Consensus Policies and Temporary Policies Specification Issue 1: Feedback from Theo Geurts (Re: Section 1.2.1)-how does a privacy service endanger the security or stability of the internet? Comments on today's call: IRT member comment-this should only be included if there is a specific purpose for this; Other IRT members-there are instances where someone acting in a manner that could endanger security/stability may be hiding behind a PP service Proposed Next Steps: If no further IRT feedback to the contrary, reasons to keep this section appear to have been identified. Issue 2: IRT member Feedback Re: Section 1.3-I think we can delete all sections in 1.3 as they deal with domain name registrations in general rather than providing a privacy service. We could say privacy providers should not practice warehousing, but that is not what it currently says. Comments from today's call: At least some of these sections appear to be relevant to PP services (see, e.g. Sections 1.3.6) Proposed Next Steps: If IRT members would like to identify any sections that they believe should be deleted, please send specific suggestions to the list this week. Specification 4: Law Enforcement Authority Disclosure Framework Specification Issue 1: Proposal to change references to "national or international law" to "applicable law" Comments from today's call: No issues raised on call Proposed next steps: Update language throughout specification if no contrary input from IRT. Issue 2: Timeline for processing/responding to "high priority" requests Current status: PPAA draft provides for two business days for providers to process LEA requests and ensure they meet minimum standards for acceptance (Section 3.2.1). If a request meets criteria for "high priority" request, provider must action the request within 24 hours (Section 4.1.2) Comments from today's call: Timeline for provider responses to high priority LEA requests was revisited. PSWG representative stated that this is too long. Some Rr representatives on call reiterated prior feedback that receipt process may require legal/outside review, and that 2 business days is appropriate timeframe. Proposed next steps: This discussion mirrors points raised in prior discussions regarding this framework (summary of most recent discussions in August, including results of IRT poll regarding potential changes from "2 business day" review period, attached). This topic will be continued next week. If there is continued disagreement among IRT stakeholders after Tuesday's call, this item will be specifically flagged for community input in the call for public comments. 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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Regrets for today's call
by Darcy Southwell Jan. 16, 2018

Jan. 16, 2018

My apologies, but I will not be able to make the 16 January call. __________ *Darcy Southwell *| Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart

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Materials, action items from today's IRT call
by Amy Bivins Jan. 12, 2018

Jan. 12, 2018

Dear Colleagues, Thanks so much for those of you who participated on today's IRT call. For those of you who could not attend, I encourage you to listen to the recording, which will be available on the wiki shortly, https://community.icann.org/display/IRT/09+January+2018. Today, we picked up our discussion of the IRT's feedback on the PPAA draft in Section 3.12, and we proceeded through the end of the text of the contract (prior to the specifications). A brief high-level summary of the input received today is below. IRT Action Items 1. If you have further input on these or any other points discussed on the call, please send them to the list this week. 2. If you have any further input on the PPAA draft, you must send this to the list this week. 3. If you have further comments related to the distinction between requirements for affiliated and non-affiliated providers in the attached chart (first distributed in December), specifically related to the suggestion from some IRT members that ICANN should revisit the possibility of having a separate agreement for affiliates, you must send this to the list this week. If ICANN does not receive further input on this, we will continue to proceed with this single agreement. ICANN Org Action Items 1. ICANN Org will begin reviewing and incorporating IRT feedback on PPAA into next PPAA draft. 2. ICANN Org will alert IRT to discussion topics for next week no later than EOD Friday. 3. ICANN Org is finalizing next draft of other implementation materials (applicant guide, Policy document) for IRT review prior to opening public comment period. ICANN Org also must provide updated PPAA specifications to IRT for discussion so that these can be finalized prior to opening public comment period. 4. Our aim is to finalize discussions on all materials identified above prior to ICANN61. Summary of IRT Input Received on 9 January Call Section 3.12: IRT members supported deleting the new text in 3.12.2 that was added to reference the LEA framework (this will be saved for the framework itself). Section 3.14: IRT members supported deleting the new text that was added to reference text from the final report. In its place, text from the final report should be added to the IP framework specification. Section 3.16 (Relay): IRT members recommended editing Section 3.16.2 to change "concerning" to "for Relay to" to narrow this provision to encompass only Relay requests. IRT members said ICANN should revisit 3.16.6, which appears to be too broad. It appears this section should apply only to section 3.16.5, and should be renumbered 3.16.5.1. Section 3.17 (Reveal): In prior feedback, some IRT members said this was inconsistent with Final Report. IRT members are invited to identify how this is substantively different than the Final Report on-list if you would like to discuss this further. IRT members also said that ICANN should revisit 3.17 to ensure that Final Report requirements (p. 70) are included regarding customer notifications and notifications regarding a provider's decision to comply with a request (or not). Section 3.19 (Record Keeping): IRT members pointed ICANN to prior feedback re: suggested language on reporting mechanism. ICANN will revisit this recommendation and also check for an update re: the reporting interface. Section 5.3 (Right to Substitute Amended Agreement): Copy edits previously suggested by Steve Metalitz-ICANN will revisit. This may have been drafted to mirror RAA, and consistency will be the goal if there is an analogous RAA provision. Section 5.5 (Termination). IRT feedback is specifically requested on Section 5.5.9-right of ICANN to terminate a PPAA where an Affiliate's PPAA or RAA is terminated. Initial IRT feedback indicated this may be too broad. Perhaps termination of affiliate agreement should be a reason to check compliance status rather than resulting in termination automatically. Section 7.4 (Negotiation Process). This could be edited to remove reference to "Stakeholder Group" and this could be addressed if a Stakeholder Group/Constituency/ETC is ever created. Section 7.4.4.3-if this is a community-appointed WG (if "stakeholder group" deleted), this reference to bearing costs of mediation should be deleted. Section 7.4.5.2. IRT members are encouraged to review this section specifically, in re: feedback on-list. Section 7.5 (Synchronization Amendment). IRT members encouraged ICANN to review text that was previously suggested (see issues list) to simplify 7.5.1 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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Additional notes, background for 9 January IRT Call
by Amy Bivins Jan. 9, 2018

Jan. 9, 2018

Dear Colleagues, In advance of our meeting on Tuesday, I'm including a few background points that may have been forgotten or lost since it's been awhile since we have discussed the upcoming PPAA sections we expect to cover during the meeting. Reviewing the IRT's feedback on the substance of the draft contract, we will likely be able to make it through the rest of the PPAA draft (not including the specifications) next week. With respect to the feedback received on PPAA Section 3.12 (abuse contact): Per discussion on IRT calls in early 2017, we began drafting this section with RAA requirements where Final Report was silent (final report mentioned "designated" rather than "dedicated" contact but was otherwise silent on specific abuse contact requirements. The IRT supported this approach at the time. We adapted RAA requirements, per IRT discussions and Final Report, to allow for abuse contact options other than an email address (per recommendation in final report--"to address increasing volumes of spam" associated with the publication of an abuse contact email address (see p. 62 of Final Report). Re: PSWG feedback--this "abuse contact" provision governs when other frameworks (LEA or IP) do not apply IRT feedback re: Section 3.12.2 is noted-I believe the edits were added in an attempt to capture the requirements of the LEA framework, but this can be handled within the framework itself. Section 3.14: This edit was proposed based on text from Final Report in the IP framework-this was discussed briefly on a prior IRT call but can be discussed further. Section 3.17: IRT feedback was that this does not read consistently with Final Report. IRT members who raised this point are asked to explain why/how they believe this is inconstant with the Final Report, as our interpretation of this text is that it has the same meaning as the Final Report. Section 3.19: This requirement was included in the Final Report. Please provide any further feedback on these or any other aspects of the PPAA and issues identified in the issues list on the list prior to our call next 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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Reminder--IRT feedback requested by 5 January on items discussed at last meeting
by Amy Bivins Jan. 2, 2018

Jan. 2, 2018

Dear Colleagues, Hello, and happy new year! This is a reminder that your feedback is requested by Friday, 5 January, on the issues discussed on the most recent IRT call (set forth in greater detail below). For next week’s meeting, on 9 January, we will pick up where you left off at the last meeting—at Section 3.12 (abuse contact) of the draft PPAA (see also starting at p. 20 on the attached issues list). We will proceed as far as we can next week on the issues list. I’m also working to put together an updated project status update so that we can see where we are on all of the project deliverables and better estimate when we will be ready for public comment, and I hope to have that ready to share with you next week. Please continue to respond to the list with issues, comments and any other feedback that you would like to add to the attached issues 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> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Caitlin Tubergen Sent: Thursday, December 21, 2017 10:40 PM To: gdd-gnso-ppsai-impl(a)icann.org Cc: Roman, Peter (CRM) <Peter.Roman(a)usdoj.gov> Subject: [Gdd-gnso-ppsai-impl] Materials, action items from Tuesday, 19 December 2017 Privacy/Proxy IRT call Dear Colleagues, Thank you for your participation on Tuesday’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/19+December+2017. During the call, we continued to go through the comments you provided on the draft PPAA. Below, please find a brief summary of the issues we discussed. As always, we continue to welcome your feedback. Please provide feedback on the issues discussed this week and last week by Friday, 5 January 2018. Data Retention * The IRT members on the call agreed to forego additional GDPR discussions at this time. All previously-flagged IRT concerns will be noted for public comment, and we will update the IRT as we receive additional guidance on GDPR matters. If a solution is developed in GDPR before the PPAA is finalized, we will work with the IRT to amend the PPAA accordingly. * In reference to section 3.2.2 and 3.2.3, Steve Metalitz suggested adding language to the effect of: “During the Term of this Agreement and for one year thereafter unless applicable law dictates a different period, Provider (itself or by its agent(s)) shall maintain the following records[.]” (Proposed new language is italicized.) Please let us know if you agree with this change and/or if you propose different language. Domain Name Cancellation * Ensure any reference to a P/P Provider cancelling/deleting a domain name is removed as Providers cannot cancel/delete names. * With respect to section 3.5.17, how should UDRP Providers/Registrars proceed in a UDRP case when an unaffiliated P/P Provider is involved? For example, should the UDRP Provider contact the unaffiliated P/P Provider to verify the underlying registrant/customer information? (Please note the registrar would not be able to provide the underlying registrant information to the UDRP Provider, as it would not have this information.) Question to the IRT: Please provide any additional suggestions/comments in relation to the unaffiliated P/P Provider and UDRP issue. Publication of Information on Websites * Section 3.8.3 – publication of fees. Theo Geurts notes this provision may be difficult for wholesale registrars. Steve Metalitz noted that the providers would be responsible for displaying provider fees, not registrar fees. Question to IRT: Please provide further information on why this provision is an issue. * Section 3.11 – some IRT members noted Providers should not be required to publish officer information on their websites. Other IRT members disagree and note this information is necessary. Question to IRT: Please provide further information on why the provision of officer information is an issue and/or why the publication of officer information is necessary. Our next IRT meeting will be Tuesday, 9 January. Michelle will be sending out a reminder for that meeting. I have attached an updated Issues List. Please continue to respond to the list with concerns, questions and ideas. I wish everyone a wonderful and restful holiday season, and I look forward to our continued collaboration in 2018! 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<mailto:caitlin.tubergen@icann.org>

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Materials, action items from Tuesday, 19 December 2017 Privacy/Proxy IRT call
by Caitlin Tubergen Dec. 22, 2017

Dec. 22, 2017

Dear Colleagues, Thank you for your participation on Tuesday’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/19+December+2017. During the call, we continued to go through the comments you provided on the draft PPAA. Below, please find a brief summary of the issues we discussed. As always, we continue to welcome your feedback. Please provide feedback on the issues discussed this week and last week by Friday, 5 January 2018. Data Retention The IRT members on the call agreed to forego additional GDPR discussions at this time. All previously-flagged IRT concerns will be noted for public comment, and we will update the IRT as we receive additional guidance on GDPR matters. If a solution is developed in GDPR before the PPAA is finalized, we will work with the IRT to amend the PPAA accordingly. In reference to section 3.2.2 and 3.2.3, Steve Metalitz suggested adding language to the effect of: “During the Term of this Agreement and for one year thereafter unless applicable law dictates a different period, Provider (itself or by its agent(s)) shall maintain the following records[.]” (Proposed new language is italicized.) Please let us know if you agree with this change and/or if you propose different language. Domain Name Cancellation Ensure any reference to a P/P Provider cancelling/deleting a domain name is removed as Providers cannot cancel/delete names. With respect to section 3.5.17, how should UDRP Providers/Registrars proceed in a UDRP case when an unaffiliated P/P Provider is involved? For example, should the UDRP Provider contact the unaffiliated P/P Provider to verify the underlying registrant/customer information? (Please note the registrar would not be able to provide the underlying registrant information to the UDRP Provider, as it would not have this information.) Question to the IRT: Please provide any additional suggestions/comments in relation to the unaffiliated P/P Provider and UDRP issue. Publication of Information on Websites Section 3.8.3 – publication of fees. Theo Geurts notes this provision may be difficult for wholesale registrars. Steve Metalitz noted that the providers would be responsible for displaying provider fees, not registrar fees. Question to IRT: Please provide further information on why this provision is an issue. Section 3.11 – some IRT members noted Providers should not be required to publish officer information on their websites. Other IRT members disagree and note this information is necessary. Question to IRT: Please provide further information on why the provision of officer information is an issue and/or why the publication of officer information is necessary. Our next IRT meeting will be Tuesday, 9 January. Michelle will be sending out a reminder for that meeting. I have attached an updated Issues List. Please continue to respond to the list with concerns, questions and ideas. I wish everyone a wonderful and restful holiday season, and I look forward to our continued collaboration in 2018! 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 Tuesday 12 December Privacy/Proxy IRT call
by Caitlin Tubergen Dec. 15, 2017

Dec. 15, 2017

Dear Colleagues: Thank you for your attendance and participation on this week’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/12+December+2017. The IRT is making its way through the attached Issues List, and I updated the Issues List to reflect Tuesday’s discussion. On our next call on Tuesday, 19 December, we will discuss the issue of data collection, retention, escrow, GDPR concerns, etc., which is next on the Issues List. Provided we conclude the discussion of data collection, we will continue to work our way through the issues list in order. Please provide any additional input you have on the topics discussed on Tuesday (summary provided below) no later than next Friday, 23 December. Summary of today’s topics, questions and action items (updated issues list, with complete IRT input, attached): Definitional Concerns The IRT members on the call seem to be in agreement that the PPAA definitions that match RAA definitions should not be changed. Specifically, these definitions include: gTLD Zone-File Data (section 1.13) Personal Data (section 1.19) Provider Approval (section 1.21) Registered Name (section 1.24) Registered Name Holder (section 1.25) Reseller (section 1.33) Registered name is “sponsored” (section 1.36) The IRT members on the call expressed no objections to these definitions: Person (section 1.18) Registration Data Directory Service (section 1.28) The following definitions require further discussion and/or amendment: Affiliated Provider (Section 1.4) (Please see my email of 13 December for further information.) Customer; Privacy Service; Proxy Service (Section 1.8; 1.22; 1.24) – The definition of customer was added for the sake of clarity and consistency since the terms beneficial user, customer, licensee, and underlying registrant were not used consistently in the Final Report. The definition of Customer is also cross-referenced in the definition of Privacy Service and Proxy Service; accordingly, these definitions are not an exact match of the Final Report/Privacy/Proxy Specification. Some IRT members expressed concerns with the removal of the term beneficial user, as there was a reason this term was used. No one on the call expressed the particular reason and/or difference between these terms. We are seeking additional feedback on the specific difference and/or concern between customer, beneficial user, underlying registrant, and licensee. It would also be helpful if you could propose definitions of licensee/beneficial user if you believe we need to add more definitions than Customer. Law Enforcement Authority (Section 1.16): IRT feedback: The language re: applicable jurisdiction should be looked at in conjunction with the LEA Framework to specify that the provider may have obligations outside the PPAA, and this definition does not negate that. Service Provider (Section 1.37): Change all references from Provider to Service Provider for consistency with the defined term. Working Group (Section 1.43): There seems to be some disagreement regarding who should comprise the Working Group – if it should just be Service Providers, or if it should include a cross-section of the community. Additionally, a few IRT members suggested deleting the phrase, “provided, that, if the Generic Names Supporting Organization (the “GNSO”) forms a stakeholder group for Service Providers (the “Provider Stakeholder Group”), then following the date of the formation of the Provider Stakeholder Group, the Provider Stakeholder Group shall appoint the representatives of the Service Providers and other members of the community to constitute the Working Group. The Working Group will serve as a working group to consult on amendments to the Service Provider Agreements (excluding bilateral amendments pursuant to Section 6.9).” Additional IRT Feedback is requested on the definitions of Affiliated Provider, Customer, Law Enforcement Authority, Privacy Provider, Proxy Provider, and Working Group. Drafting Concerns Sections 2.3.2 and 2.3.3 General Obligations of ICANN– no IRT members on the call expressed concerns with this section. Section 2.4 Use of ICANN-accredited Providers – IRT member (Margie Milam) suggestion: “intends to abide” is weak language – consider redrafting to “shall abide” or “shall reasonably abide” Section 3.1 General Obligations of Service Provider – IRT members recommend keeping WILL, instead of MAY, in the provision: During the Term of this Agreement, [Service] Provider agrees that it will provide the Services in accordance with this Agreement As always, if you would like to raise any other issues or feedback, please feel free to send to the list at any time. I look forward to Tuesday’s call, where we will continue working our way through the issues list. Kind regards, Caitlin

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Suggested Definitions for 1.4 & 1.5
by Darcy Southwell Dec. 14, 2017

Dec. 14, 2017

These are the revised definitions I would propose from today's meeting regarding Affiliate Provider and Affiliated Registrar: 1.3 “Affiliate” means a Person that, directly or indirectly, through one or more intermediaries, Controls, is controlled by, or is under common control with, the Person specified. 1.4 "Affiliated Service Provider" is a Service Provider that is an Affiliate of a Registrar. 1.5. "Affiliated Registrar" is a Registrar that is an Affiliate of a Service Provider." 1.37 “Service Provider” means a Person that provides Privacy Services or Proxy Services, who that has been Accredited and entered into an agreement with ICANN substantially similar to this Agreement. Thanks, Darcy __________ *Darcy Southwell *| Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart

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Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Materials, action items from 17 Oct Privacy/Proxy IRT call
by Caitlin Tubergen Dec. 12, 2017

Dec. 12, 2017

Dear Colleagues, Further to Sara’s suggestion in this message and the accompanying discussion on last Tuesday’s call, we have compiled a table which breaks down the sections of the draft PPAA, and divides the sections into affiliated and unaffiliated requirements. We can use this table for discussion purposes as we begin going through the updated issues list on tomorrow’s call. Thank you! 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 From: Sara Bockey <sbockey(a)godaddy.com> Date: Friday, December 1, 2017 at 10:09 AM To: Caitlin Tubergen <caitlin.tubergen(a)icann.org>, "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Cc: "Roman, Peter (CRM)" <Peter.Roman(a)usdoj.gov>, Sara Bockey <sbockey(a)godaddy.com>, 'Darcy Southwell' <darcy.southwell(a)endurance.com> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Hi all, In my last-minute reviewing of the PPAA, I’ve had a few additional thoughts: We need to revisit PPAA, Spec 2: Customer Data Accuracy. This entire Spec needs to be revisited and made clearer since the entire spec is dependent on whether or not the Service Provider is affiliated or non-affiliated. It’s very disjointed, it starts out Section 1, this is what you need to do, then in Section 3, it says you don’t need to do this if you are an affiliated Provider, and then in Section 4 it goes back to this is what you need to do and forgets about section 3. It seems to me that this entire section is dependent on if there is an Affiliated Registrar. This section got me thinking and IMHO, in addition to going thru every comment that has been submitted and sorting through those issues, I think we need to take a serious look at the approach of the PPAA. I think the document as it stands is not recognizing the Service Provider as an Affiliate of an ICANN accredited Registrar. I’m wondering if what we really need is 2 separate PPAAs – one for an Affiliated Service Provider and one for a Non-Affiliated Service Provider. For the Affiliated Service Provider, it should set out at the very beginning the affiliate relationship, and both parties would sign. The basic idea would be something like: Service Provider X, as an Affiliate of ICANN accredited Registrar A, enters into this PPAA to provide a privacy/proxy service. Registrar A, as a party to this agreement, agrees to uphold its obligations under the RAA and its related consensus policies. Should the relationship between Service Provider X and Registrar A cease, so shall this agreement, and Service Provider X will have ___ number of days to secure a new affiliate registrar and enter into a new Affiliated PPAA or complete the Non-Affiliated process and sign the Non-Affiliate PPAA. It needs work, I know, but just trying to illustrate the idea. I think this would allow the affiliated agreement to be considerably more light weight. The Non-Affiliate PPAA would be more in line with what we have now (and, granted, would need additional work). If the Affiliate Provider became unaffiliated, it would need to go thru an accreditation process to ensure it meet the requirements. So there would need to be 2 accreditation procedures, but again I’m thinking the Affiliated process would be relatively light weight based on the relationship of the provider to the accredited registrar. Also, we need to correct some of the language in the PPAA. Specifically, as I’ve stated numerous times before, I think staff’s use of “Customer” in place of RNH is problematic when the PPAA is an extension of/referenced in the RAA, particularly when considering the above line of thinking. The 2013 RAA 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. This is a service for the RNH, provided via an Affiliate Registrar, the use of “customer” is problematic. I’ll admit I’ve not thought thru all the issues and this is kind of loose, but it’s an idea that came to mind and something we might ought to consider so I’m putting a marker down to discuss the above in case it offers a better path forward. Happy to hear what others think. 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: Caitlin Tubergen <caitlin.tubergen(a)icann.org> Date: Thursday, November 30, 2017 at 5:05 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org>, Sara Bockey <sbockey(a)godaddy.com>, 'Darcy Southwell' <darcy.southwell(a)endurance.com> Cc: "Roman, Peter (CRM)" <Peter.Roman(a)usdoj.gov> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Thank you, Steve, and thank you to the registrars who submitted comments. I will compile all of the comments, and we can begin going through the comments on Tuesday’s call. If any other IRT members have comments on the draft PPAA, please submit them by the deadline of Friday, 1 December. 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 From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of "Metalitz, Steven" <met(a)msk.com> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Thursday, November 30, 2017 at 2:16 PM To: 'Sara Bockey' <sbockey(a)godaddy.com>, 'Darcy Southwell' <darcy.southwell(a)endurance.com>, "'gdd-gnso-ppsai-impl(a)icann.org'" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call PPSAI colleagues, I offer the following comments and suggested edits regarding the Oct. 20 redline version of the PPAA. I may have a few other suggestions by tomorrow’s deadline, and will definitely have responses later to some of the other proposed edits that have been sent to the list. (And thanks to Theo and colleagues for their comprehensive review of the document!) First, I would reiterate the suggestions made in my Oct. 21 posting to the list, as follows: Subsection 3.5.3.15: strike “should” and insert “shall,” for consistency with parallel provisions throughout this section 3.5. Section 3.7, third line from the bottom: “employee” should be “employ.” Section 3.17.1: I suggest adding the words “as applicable” or “to the extent applicable” at the end of the section. Not every Disclosure or Publication request that Provider receives will fall under the IP or LEA disclosure frameworks. Section 5.7.3: the notice that the suspended Provider must send to customers should specify “that it is unable to offer or provide the Services for any new registrations” (adding the last 4 words). A suspended Provider can (and indeed must) provide the Services to its current customers. [Note that the phrasing “any additional registrations” might be more accurate here, and in the corresponding provision of 5.7.1 --- otherwise it might be possible for a suspended provider to being providing services for the first time to an existing registration whose registrant decides to engage a service.] Here are some additional suggestions: Section 1.43: strike “comprising the Working Group,” insert “representatives of the Service Providers.” This issue is noted on page 2 of the Discussion Items document. Section 3.5.3.3: since this has to do with p/p services and not with registration per se, the references to “initial registration and each renewal registration” should be changed to something like “each initial agreement to provide Services and each renewal or extension of such agreement.” I believe this is also responsive to Theo’s sticky note on the RrSG redline for this section. Section 3.8.1 (specifying what needs to be stated on request forms) should include a cross-reference to section 3.8.2 (requiring publication of links to request forms in some circumstances). Alternatively, perhaps the order of these two sections should be reversed. Section 3.8.5.5 needs some rephrasing. Reveal is not a defined term in the PPAA, and the provider does not itself Publish data in the RDS (the registrar or registry does that), but can cause it to be Published. This may a rare instance in which use of the passive voice may be preferable (“the circumstances under which the Customer’s identity or contact data will be published in the RDDS….”). Section 3.19: substitute “shall” for “should.” In fact the entire document should be reviewed to see where this change is needed. Section 5.3: this is another issue I raised in my Oct. 21 posting: “Section 5.3 does not give ICANN the right to substitute the new version of the agreement, it gives that right to the provider. Furthermore, 5.3 addresses the scenario in which the new agreement is swapped in during the term of the current agreement. The point I was trying to raise on the call (and I am sorry if this was not clear) is ensuring that all renewals of the agreement at the end of the term reflect the most recent version. As currently drafted, section 5.2 seems to give the provider the option of renewing under the terms of the old agreement (“under the terms and conditions of this agreement”), even if it has been superseded by a new form of agreement that is materially different. This could be fixed by adding a subsection 5.2.5 along the following lines: ‘5.2.5: this Agreement has been superseded by a revised form accreditation agreement for the provision of the Services (“Updated PPAA”) that is materially different from this Agreement, in which case the right of renewal provided by this section shall be under the terms and conditions of the Updated PPAA.’” Section 5.7.4: consider inserting at the end of the first sentence “or its invocation of section 5.5.7,” which is another path ICANN could take to deal with the situation of an uncured “endangerment” scenario. Section 7.4.1: shouldn’t the Working Group be the party to receive the notice re revision of the Agreement? This would be consistent with the rest of section 7.4. Glad to try to answer any questions about these. Steve Metalitz Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com Mitchell Silberberg & Knupp LLP | www.msk.com[msk.com] 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Metalitz, Steven Sent: Tuesday, November 07, 2017 11:42 AM To: 'Sara Bockey'; Darcy Southwell; gdd-gnso-ppsai-impl(a)icann.org Subject: RE: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call I agree with a lot of what Darcy says. Let me make sure my view is clearly stated. Most of the items Darcy identifies are completely appropriate for discussion in our team before the documents are finalized. These issues include: perceived discrepancies between the WG Final Report and the implementation documents; loose ends in the Law Enforcement disclosure framework; and clarifying the status of each of the four documents under review. I support addressing these points on our next call so that we can continue to make progress. And based on the postings made to our list over the last couple of weeks, I would certainly be comfortable with some relaxation of the deadline for proposing edits to the accreditation agreement – if necessary, to December 1. My concerns are focused primarily on the suggestion that we can’t move forward until we determine whether our recommendations are GDPR-compliant. To me that sounds like some on the IRT want to suspend work until ICANN’s separate work on GDPR is concluded. If that is not what is meant, then I would ask proponents of that view to clarify just how they think we should proceed at this point. I am also sad to see the IRTP-C issue brought up again. I thought we had reached agreement that the current suspension of ICANN enforcement of this aspect of that policy could be continued until an appropriate group is formed to address it; or put another way, that we could proceed to get our PPSAI implementation plan out for public comment without delaying it until the IRTP-C issue is resolved. That is my recollection, anyway, but if I am mistaken then please show me how. Finally I will repeat my question of whether our call time on 11/14 remains at 1400 UTC or whether it will be moved an hour later to preserve the usual start time in most Northern Hemisphere time zones. Steve Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com Mitchell Silberberg & Knupp LLP | www.msk.com[msk.com] 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Sara Bockey [mailto:sbockey@godaddy.com] Sent: Tuesday, November 07, 2017 11:07 AM To: Darcy Southwell; gdd-gnso-ppsai-impl(a)icann.org; Metalitz, Steven Cc: Sara Bockey Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Well said, Darcy. Agree 100%. 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: Darcy Southwell <darcy.southwell(a)endurance.com> Date: Tuesday, November 7, 2017 at 8:47 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org>, "Metalitz, Steven" <met(a)msk.com>, Sara Bockey <sbockey(a)godaddy.com> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call I agree with Theo. The scope has changed and implementation is impacted by GDPR. While I appreciate that Steve wants to move forward expeditiously, I don’t believe we can do so without jeopardizing the creation of an effective program. Further, in just the last week or so, issues have been raised about implementation language contradicting the policy. The role of an IRT is to implement the consensus policy produced in the PDP and we need to spend sufficient time reviewing and discussing the implementation to ensure we’re not changing policy. Similarly, I think there were questions raised about the proposed framework Public Safety Working Group. In addition to policy creep, I believe concerns were expressed that staff failed to modify the proposed framework based on the feedback from IRT participants. Rather than picking through the documents line by line, it seems like we should step back and have a discussion about the concepts to ensure we’re making progress toward an effective implementation that reflects the policy. There have also been repeated questions raised about the over-engineering of this implementation. Because many of the meetings have focused on reviewing language from a specific section (rather than reviewing issues as whole items), it seems like we haven’t gotten past this issue, and should probably take a fresh look at that to ensure we’re not making this implementation more complicated than it needs to be. We all know that doesn’t lead us to a better implementation. Right now, we have four draft documents for review/input: (1) accreditation agreement, (2) de-accreditation process, (3) applicant guide, and (4) data escrow specification. For many members, these require operational and legal review (at a minimum). Many registrars have commented that 1 December is the earliest they can provide full feedback given the complexity of these documents (although not all have committed to that date). Given these issues, as well as the fact that the privacy/proxy challenge stemming from IRTP-C needs to be added to this IRT for a solution, we need to take a step back and address these critical issues first. This isn’t about derailing the IRT; it’s about ensuring we don’t create an implementation that’s an operational nightmare for providers as well as registrants and end users – and that means addressing these critical issues first. Thanks, Darcy From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of theo geurts <gtheo(a)xs4all.nl> Reply-To: <gdd-gnso-ppsai-impl(a)icann.org> Date: Monday, November 6, 2017 at 12:27 PM To: <gdd-gnso-ppsai-impl(a)icann.org>, "Metalitz, Steven" <met(a)msk.com>, Sara Bockey <sbockey(a)godaddy.com> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Hi Steve, Vicky, Now your argument is logical and makes sense. Yes, as I mentioned before, CPH's will implement privacy services on many different levels to comply with the GDPR, we agree here. My biggest problem with the PPSAI IRT is the changing dynamics. The WG contemplated and discussed and made recommendations based on a very fixed situation. In my opinion, privacy services should not be used as bandaid for data protection problems. Complying with data protection laws was not the driving force during the WG days, and now it is. I think the scope of the IRT has changed and we should deal with this before we move on. We need to think a little smarter and deeper here before we unleash this to many contracted parties who have zero experience with these services and will be required to implement this to comply with data protection laws. So how do we do that? I think a fixed set of procedures and contractual agreements are essential, yet I do not want us to enter into a situation that causes more issues and forces providers into a situation that we need to ask compliance to defer. https://www.icann.org/resources/pages/contractual-compliance-statement-2017… I think that scenario is unwanted for everyone on the IRT is it not? Thanks, Theo Geurts On 6-11-2017 19:40, Metalitz, Steven wrote: I strongly second Vicky’s comments. The ongoing ICANN work re GDPR is of course very important, but let’s not let it derail progress on the path we have moved so far along toward a P/P service accreditation framework to present to the community. In that regard, I have some sympathy (empathy?) for those requesting a relaxation of the comment deadline in light of so much other activity demanding our attention. May I suggest that we try to get as many proposed edits onto the list before our November 14 call (with much thanks to those who have already done so), with the goal of dealing with them then if possible, but leaving the door open for further edits over the next couple of weeks if necessary. Finally, some ICANN groups are adjusting the scheduling of their calls to reflect the return to standard time in North America and Europe. Is this group doing so as well? If our calls stay at 1400 UTC that is now 9 am EST and 6 am for those on Pacific time. Moving to 1500 UTC would retain the pre-existing local start times, I believe. Steve Metalitz Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com Mitchell Silberberg & Knupp LLP | www.msk.com[msk.com] 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Victoria Sheckler Sent: Tuesday, October 31, 2017 5:55 PM To: gdd-gnso-ppsai-impl(a)icann.org; Sara Bockey Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Please note that ICANN’s work on GDPR’s on a separate track and that one thing we know almost for sure is that the adoption of rational, predictable rules for privacy/proxy will be more important post-GDPR than it ever was. So please let’s get those rules in place as expeditiously as possible. On 30-10-2017 11:32, Sara Bockey wrote: 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… 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. 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. 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 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. 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[community.icann.org]. 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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

4 3

FW: [Ext] RE: Agenda + Updated Draft PPAA with IRT comments
by Caitlin Tubergen Dec. 7, 2017

Dec. 7, 2017

From: "Roman, Peter (CRM)" <Peter.Roman(a)usdoj.gov> Date: Tuesday, December 5, 2017 at 5:40 AM To: Caitlin Tubergen <caitlin.tubergen(a)icann.org>, "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Ext] RE: Agenda + Updated Draft PPAA with IRT comments Good morning all – I have a few additional comments on the draft: Overall – this agreement seems to misunderstand the point of having a high priority request mechanism. High priority requests are usually emergencies where victims are moments away from danger. Not requiring immediate responses to these requests renders them moot. A request that is answered within 24 hours, but 20 hours after the victim is dead, does not respect the importance of the request or the imminence of the danger. 3.12.2 - If the abuse contact point is not monitored 24/7, how are providers going to respond to high priority requests in time? SPECIFICATION 5: LAW ENFORCEMENT AUTHORITY DISCLOSURE FRAMEWORK SPECIFICATION 3.1 – This is the same issue as for 3.12.2 in the main bod of the agreement, if the point of contact is not required to be available 24/7, it defeats the purpose of the high priority requests. 3.2.1 – This part of the receipt process combined with 4.1 creates a two day window before providers have to even address whether a request is high priority, again defeating the purpose of having a high priority request. 4.1.1 – By waiting to respond until after the Receipt Process is complete, which can take up to two days under 3.2.1, the agreement renders the high priority request provisions moot. 4.1.2 – Responding to high priority requests within 24 hours is not sufficient. A request that is answered within 24 hours, but 20 hours after the victim is dead, does not respect the importance of the request or the imminence of the danger. High priority requests need to be responded to more or less immediately. 4.3.2 – The Provider should be required to disclose changes to the timeframe for notification of the Customer to LEA Requestors with current requests (i.e., “should” should be “must”). If the Customer is a target, notifying the Customer without alerting LEA can lead to the Customer destroying evidence, fleeing, or even threatening or killing informants who led law enforcement to the Customer’s account in the first place. 5.1 – I do not understand the purpose of this provision. LEA is not a party to this agreement and the agreement has no ability to bind LEA actions if the Provider fails to respond to a request. 6.2 – I do not understand the purpose of this provision either. LEA is not a party to this agreement and the agreement has no ability to bind LEA use of the evidence provided by the Provider. Peter Roman Senior Counsel Computer Crime & Intellectual Property Section Criminal Division Department of Justice 1301 New York Ave., NW Washington, DC 20530 (202) 305-1323 peter.roman(a)usdoj.gov From: Caitlin Tubergen [mailto:caitlin.tubergen@icann.org] Sent: Monday, December 4, 2017 11:36 PM To: gdd-gnso-ppsai-impl(a)icann.org Cc: Roman, Peter (CRM) <Peter.Roman(a)CRM.USDOJ.GOV> Subject: Agenda + Updated Draft PPAA with IRT comments Greetings, Colleagues. Thank you for all of your input on the draft Privacy and Proxy Service Provider Accreditation Agreement (“PPAA”). Attached, you will find an updated PPAA, which incorporates the comments received. I am also working on updating the issues list and will be distributing the list some time tomorrow. For tomorrow’s call, we can begin by discussing some of the high-level issues some of the IRT members have raised. Specifically: The concern that the text of the PPAA does not match the WG’s recommendations The idea of having two PPAAs: one for affiliated providers and one for unaffiliated providers The IRT’s preferred path forward for dealing with the comments received Additionally, I’d like to note two things. First, further to Darcy’s message today, the GNSO Council recently voted to move the Transfer Policy (IRTP-C) issue for discussion within the PPSAI IRT. I believe the Council directed this issue to be discussed during the public comment period. Darcy, please feel free to add additional context either on the list or on tomorrow’s call. Lastly, there have been several mentions of GDPR as a potential issue/barrier to the PPSAI implementation. I would like to note that ICANN has engaged legal experts to analyze the impact the European Union General Data Protection Regulation (“GDPR”) will have on various data processing activities under ICANN policies and contracts. Such policies and contracts require or permit various entities that participate in the gTLD domain name system, including registries and registrars, to collect, create, retain, escrow, and publish a variety of personal data elements related to registry/registrar operations, domain name registrations, and registrants. The legal review and analysis is being conducted in iterative phases, and ICANN gathered questions from community discussions and submissions to submit to the legal experts for possible discussion in Part 2 of the analysis. One of the questions included the following: “ICANN org is working with the community to develop implementation details for consensus policy recommendations governing the accreditation of privacy and proxy providers. How should GDPR requirements be factored into developing the accreditation process?” We will certainly keep you apprised of any feedback we receive. See you on our call tomorrow. Kind regards, Caitlin

4 8

Agenda + Updated Draft PPAA with IRT comments
by Caitlin Tubergen Dec. 5, 2017

Dec. 5, 2017

Greetings, Colleagues. Thank you for all of your input on the draft Privacy and Proxy Service Provider Accreditation Agreement (“PPAA”). Attached, you will find an updated PPAA, which incorporates the comments received. I am also working on updating the issues list and will be distributing the list some time tomorrow. For tomorrow’s call, we can begin by discussing some of the high-level issues some of the IRT members have raised. Specifically: The concern that the text of the PPAA does not match the WG’s recommendations The idea of having two PPAAs: one for affiliated providers and one for unaffiliated providers The IRT’s preferred path forward for dealing with the comments received Additionally, I’d like to note two things. First, further to Darcy’s message today, the GNSO Council recently voted to move the Transfer Policy (IRTP-C) issue for discussion within the PPSAI IRT. I believe the Council directed this issue to be discussed during the public comment period. Darcy, please feel free to add additional context either on the list or on tomorrow’s call. Lastly, there have been several mentions of GDPR as a potential issue/barrier to the PPSAI implementation. I would like to note that ICANN has engaged legal experts to analyze the impact the European Union General Data Protection Regulation (“GDPR”) will have on various data processing activities under ICANN policies and contracts. Such policies and contracts require or permit various entities that participate in the gTLD domain name system, including registries and registrars, to collect, create, retain, escrow, and publish a variety of personal data elements related to registry/registrar operations, domain name registrations, and registrants. The legal review and analysis is being conducted in iterative phases, and ICANN gathered questions from community discussions and submissions to submit to the legal experts for possible discussion in Part 2 of the analysis. One of the questions included the following: “ICANN org is working with the community to develop implementation details for consensus policy recommendations governing the accreditation of privacy and proxy providers. How should GDPR requirements be factored into developing the accreditation process?” We will certainly keep you apprised of any feedback we receive. See you on our call tomorrow. Kind regards, Caitlin

1 0

Referral of IRT Part C Privacy/Proxy Registration Implementation Issues to PPSAI IRT
by Darcy Southwell Dec. 5, 2017

Dec. 5, 2017

All, The GNSO Council passed the below resolution during the 30 November 2017 meeting. As GNSO Council Liaison to the PPSAI IRT, I'm communicating this to the entire IRT. Please not that this work is expected to be undertaken only after the upcoming PPSAI IRT comment period. *Motion to Refer IRTP Part C Privacy / Proxy Registrations Implementation Issues to PPSAI IRT* Submitted by Darcy Southwell Seconded by Donna Austin 1. The Generic Names Supporting Organization (GNSO) Council sent a letter (see https://gnso.icann.org/en/correspondence/bladel-to- crocker-01dec16-en.pdf) to the ICANN Board on 1 December 2016 regarding implementation concerns with the Inter-Registrar Transfer Policy ("Transfer Policy") – Part C for privacy/proxy registrations. Specifically, the concerns relate to whether the addition/removal of a privacy/proxy service potentially triggers the 60-day inter-registrar transfer lock described in the updated Transfer Policy. The policy recommendations were silent with respect to the addition/removal of privacy/proxy services, and at the time the policy was implemented, the current issue and potential harms described by the GNSO Council were not brought to ICANN org's attention. 2. In this letter, the GNSO Council requested the Board to instruct ICANN Org to work with the Registrar Stakeholder Group and other interested parties to evaluate alternatives for the implementation concerns related to Transfer Policy Part C. 3. On 16 March 2017, the Board instructed the ICANN President and CEO, or his designee(s), to work with the Registrar Stakeholder Group and other interested parties to evaluate alternatives for the implementation concerns related to Transfer Policy Part C and to report back to the GNSO Council with the results of the discussion.” During this time, enforcement of the policy related to this specific issue has been deferred. 4. The Registrar Stakeholder Group discussed this issue and reached out to other interested parties to evaluate alternatives for the implementation concerns related to IRTP Part C and recommended that this issue is further evaluated by the Privacy & Proxy Services Accreditation Issues Implementation Review Team (PPSAI IRT) as this group is best placed to determine if/how implementation of IRTP Part C for privacy / proxy registrations can be carried out. Resolved, 1. The GNSO Council directs the PPSAI IRT to consider the issue of privacy/proxy registrations and IRTP Part C as outlined in the annex to the GNSO Council letter (see https://gnso.icann.org/en/correspondence/bladel-to- crocker-01dec16-en.pdf) and to put forward recommendations for implementation that are consistent with the IRTP Part C policy recommendations as well as the PPSAI policy recommendations. 2. The GNSO Council requests that this work be undertaken only after the upcoming PPSAI IRT comment period, and that if it appears as though it will cause any significant or unreasonable delay in implementation of privacy/proxy service accreditation implementation, that the GNSO Council Liaison must alert the Council. 3. The GNSO Council encourages registrars and other impacted parties to join the PPSAI IRT to collaborate in these discussions. 4. The GNSO Council requests the GNSO Council Liaison to the PPSAI IRT (in consultation with ICANN org and the IRT) provides regular updates on the timeline for incorporating the issue of privacy/proxy registrations and the Transfer Policy into the work of the PPSAI implementation plan. Where issues emerge during implementation that may require possible policy discussion, the Council requests GNSO Council Liaison to the PPSAI IRT to escalate these issues using the designated procedure outlined in the Final Recommendations Report on Policy & Implementation. 5. The GNSO Council requests the GNSO Council Liaison to the PPSAI IRT to communicate this decision to the PPSAI IRT as soon as possible. Vote Results[gnso.icann.org] <https://urldefense.proofpoint.com/v2/url?u=https-3A__gnso.icann.org_en_meet…> Best, Darcy __________ *Darcy Southwell *| Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart

2 1

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

14 39

Further comments on PPAA WAS RE: Materials, action items from 17 Oct Privacy/Proxy IRT call
by Metalitz, Steven Dec. 1, 2017

Dec. 1, 2017

Here are a few additional suggestions on the PPAA. As before I am focusing primarily on flagging issues not already identified in the various submissions from registrar participants in the IRT; I am sure we will have a chance to go through those as part of the process. Again I might possibly have a few more before the end of the day. Spec 2 (Customer Data Accuracy): in paragraph 6, after “clientTransferProhibited,” insert “by Registrar.” I think this would also address the point Theo raises in his sticky note. Spec 3 (RDDS labeling): Some of section 1 may have been carried over a bit too glibly from the corresponding RAA provision. Many of the elements added in the staff’s redline (after Domain Name) are the “thin Whois” data elements related to the underlying registration, not to provision of the Services. Would an unaffiliated Provider necessarily know all this information (other than by getting it from the registrar or registry Whois)? Additionally, shouldn’t the next group of data elements refer to Customer Name, Customer Organization, etc. rather than Registrant Name, etc.? For a proxy service, all (and for a privacy service, almost all ) of this data pertaining to the Registrant is the Provider’s contact data. What we want here is the obligation of Provider to collect a full set of Customer data so that (among other things) this data can be conveniently loaded into Whois if the p/p Services are terminated (i.e., if Publication occurs), or can be communicated to a requester under appropriate circumstances. Spec 5 (LE Authority Disclosure): for most of this we need the input from PSWG, but pending that I’d suggest that the word “applicable” be inserted before “national” in 4.2.2.2. Spec 6 (IP Disclosure Framework): I’ll respond separately to the registrar comments on this but note that there are a few places where we reference rights holders that are not individuals with respect to where they are incorporated. Such entities might take a legal form other than a corporation (e.g., partnership) so in each place we should say “incorporated or organized.” This has already been done in 2.3.3. This issue occurs in 2.1.6.3, 2.2.7.4, 2.3.6.3, and there may be other places. Also, 3.3.1 might better read: “Provider has already caused Customer contact details to be Published in RDDS as the result of termination of the Services;”. The Provider is not actually the one who publishes Whois data, that is the Registrar (and Registry). I believe RDDS is the more future-proof term than Whois and this is reflected in the definition of Publication in 1.23. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Metalitz, Steven Sent: Thursday, November 30, 2017 5:16 PM To: 'Sara Bockey'; 'Darcy Southwell'; 'gdd-gnso-ppsai-impl(a)icann.org' Subject: RE: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call PPSAI colleagues, I offer the following comments and suggested edits regarding the Oct. 20 redline version of the PPAA. I may have a few other suggestions by tomorrow’s deadline, and will definitely have responses later to some of the other proposed edits that have been sent to the list. (And thanks to Theo and colleagues for their comprehensive review of the document!) First, I would reiterate the suggestions made in my Oct. 21 posting to the list, as follows: Subsection 3.5.3.15: strike “should” and insert “shall,” for consistency with parallel provisions throughout this section 3.5. Section 3.7, third line from the bottom: “employee” should be “employ.” Section 3.17.1: I suggest adding the words “as applicable” or “to the extent applicable” at the end of the section. Not every Disclosure or Publication request that Provider receives will fall under the IP or LEA disclosure frameworks. Section 5.7.3: the notice that the suspended Provider must send to customers should specify “that it is unable to offer or provide the Services for any new registrations” (adding the last 4 words). A suspended Provider can (and indeed must) provide the Services to its current customers. [Note that the phrasing “any additional registrations” might be more accurate here, and in the corresponding provision of 5.7.1 --- otherwise it might be possible for a suspended provider to being providing services for the first time to an existing registration whose registrant decides to engage a service.] Here are some additional suggestions: Section 1.43: strike “comprising the Working Group,” insert “representatives of the Service Providers.” This issue is noted on page 2 of the Discussion Items document. Section 3.5.3.3: since this has to do with p/p services and not with registration per se, the references to “initial registration and each renewal registration” should be changed to something like “each initial agreement to provide Services and each renewal or extension of such agreement.” I believe this is also responsive to Theo’s sticky note on the RrSG redline for this section. Section 3.8.1 (specifying what needs to be stated on request forms) should include a cross-reference to section 3.8.2 (requiring publication of links to request forms in some circumstances). Alternatively, perhaps the order of these two sections should be reversed. Section 3.8.5.5 needs some rephrasing. Reveal is not a defined term in the PPAA, and the provider does not itself Publish data in the RDS (the registrar or registry does that), but can cause it to be Published. This may a rare instance in which use of the passive voice may be preferable (“the circumstances under which the Customer’s identity or contact data will be published in the RDDS….”). Section 3.19: substitute “shall” for “should.” In fact the entire document should be reviewed to see where this change is needed. Section 5.3: this is another issue I raised in my Oct. 21 posting: “Section 5.3 does not give ICANN the right to substitute the new version of the agreement, it gives that right to the provider. Furthermore, 5.3 addresses the scenario in which the new agreement is swapped in during the term of the current agreement. The point I was trying to raise on the call (and I am sorry if this was not clear) is ensuring that all renewals of the agreement at the end of the term reflect the most recent version. As currently drafted, section 5.2 seems to give the provider the option of renewing under the terms of the old agreement (“under the terms and conditions of this agreement”), even if it has been superseded by a new form of agreement that is materially different. This could be fixed by adding a subsection 5.2.5 along the following lines: ‘5.2.5: this Agreement has been superseded by a revised form accreditation agreement for the provision of the Services (“Updated PPAA”) that is materially different from this Agreement, in which case the right of renewal provided by this section shall be under the terms and conditions of the Updated PPAA.’” Section 5.7.4: consider inserting at the end of the first sentence “or its invocation of section 5.5.7,” which is another path ICANN could take to deal with the situation of an uncured “endangerment” scenario. Section 7.4.1: shouldn’t the Working Group be the party to receive the notice re revision of the Agreement? This would be consistent with the rest of section 7.4. Glad to try to answer any questions about these. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Metalitz, Steven Sent: Tuesday, November 07, 2017 11:42 AM To: 'Sara Bockey'; Darcy Southwell; gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: RE: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call I agree with a lot of what Darcy says. Let me make sure my view is clearly stated. Most of the items Darcy identifies are completely appropriate for discussion in our team before the documents are finalized. These issues include: perceived discrepancies between the WG Final Report and the implementation documents; loose ends in the Law Enforcement disclosure framework; and clarifying the status of each of the four documents under review. I support addressing these points on our next call so that we can continue to make progress. And based on the postings made to our list over the last couple of weeks, I would certainly be comfortable with some relaxation of the deadline for proposing edits to the accreditation agreement – if necessary, to December 1. My concerns are focused primarily on the suggestion that we can’t move forward until we determine whether our recommendations are GDPR-compliant. To me that sounds like some on the IRT want to suspend work until ICANN’s separate work on GDPR is concluded. If that is not what is meant, then I would ask proponents of that view to clarify just how they think we should proceed at this point. I am also sad to see the IRTP-C issue brought up again. I thought we had reached agreement that the current suspension of ICANN enforcement of this aspect of that policy could be continued until an appropriate group is formed to address it; or put another way, that we could proceed to get our PPSAI implementation plan out for public comment without delaying it until the IRTP-C issue is resolved. That is my recollection, anyway, but if I am mistaken then please show me how. Finally I will repeat my question of whether our call time on 11/14 remains at 1400 UTC or whether it will be moved an hour later to preserve the usual start time in most Northern Hemisphere time zones. Steve [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Sara Bockey [mailto:sbockey@godaddy.com] Sent: Tuesday, November 07, 2017 11:07 AM To: Darcy Southwell; gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>; Metalitz, Steven Cc: Sara Bockey Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Well said, Darcy. Agree 100%. 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: Darcy Southwell <darcy.southwell(a)endurance.com<mailto:darcy.southwell@endurance.com>> Date: Tuesday, November 7, 2017 at 8:47 AM To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>>, "Metalitz, Steven" <met(a)msk.com<mailto:met@msk.com>>, Sara Bockey <sbockey(a)godaddy.com<mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call I agree with Theo. The scope has changed and implementation is impacted by GDPR. While I appreciate that Steve wants to move forward expeditiously, I don’t believe we can do so without jeopardizing the creation of an effective program. Further, in just the last week or so, issues have been raised about implementation language contradicting the policy. The role of an IRT is to implement the consensus policy produced in the PDP and we need to spend sufficient time reviewing and discussing the implementation to ensure we’re not changing policy. Similarly, I think there were questions raised about the proposed framework Public Safety Working Group. In addition to policy creep, I believe concerns were expressed that staff failed to modify the proposed framework based on the feedback from IRT participants. Rather than picking through the documents line by line, it seems like we should step back and have a discussion about the concepts to ensure we’re making progress toward an effective implementation that reflects the policy. There have also been repeated questions raised about the over-engineering of this implementation. Because many of the meetings have focused on reviewing language from a specific section (rather than reviewing issues as whole items), it seems like we haven’t gotten past this issue, and should probably take a fresh look at that to ensure we’re not making this implementation more complicated than it needs to be. We all know that doesn’t lead us to a better implementation. Right now, we have four draft documents for review/input: (1) accreditation agreement, (2) de-accreditation process, (3) applicant guide, and (4) data escrow specification. For many members, these require operational and legal review (at a minimum). Many registrars have commented that 1 December is the earliest they can provide full feedback given the complexity of these documents (although not all have committed to that date). Given these issues, as well as the fact that the privacy/proxy challenge stemming from IRTP-C needs to be added to this IRT for a solution, we need to take a step back and address these critical issues first. This isn’t about derailing the IRT; it’s about ensuring we don’t create an implementation that’s an operational nightmare for providers as well as registrants and end users – and that means addressing these critical issues first. Thanks, Darcy From: <gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of theo geurts <gtheo(a)xs4all.nl<mailto:gtheo@xs4all.nl>> Reply-To: <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Monday, November 6, 2017 at 12:27 PM To: <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>>, "Metalitz, Steven" <met(a)msk.com<mailto:met@msk.com>>, Sara Bockey <sbockey(a)godaddy.com<mailto:sbockey@godaddy.com>> Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Hi Steve, Vicky, Now your argument is logical and makes sense. Yes, as I mentioned before, CPH's will implement privacy services on many different levels to comply with the GDPR, we agree here. My biggest problem with the PPSAI IRT is the changing dynamics. The WG contemplated and discussed and made recommendations based on a very fixed situation. In my opinion, privacy services should not be used as bandaid for data protection problems. Complying with data protection laws was not the driving force during the WG days, and now it is. I think the scope of the IRT has changed and we should deal with this before we move on. We need to think a little smarter and deeper here before we unleash this to many contracted parties who have zero experience with these services and will be required to implement this to comply with data protection laws. So how do we do that? I think a fixed set of procedures and contractual agreements are essential, yet I do not want us to enter into a situation that causes more issues and forces providers into a situation that we need to ask compliance to defer. https://www.icann.org/resources/pages/contractual-compliance-statement-2017…<https://www.icann.org/resources/pages/contractual-compliance-statement-2017…> I think that scenario is unwanted for everyone on the IRT is it not? Thanks, Theo Geurts On 6-11-2017 19:40, Metalitz, Steven wrote: I strongly second Vicky’s comments. The ongoing ICANN work re GDPR is of course very important, but let’s not let it derail progress on the path we have moved so far along toward a P/P service accreditation framework to present to the community. In that regard, I have some sympathy (empathy?) for those requesting a relaxation of the comment deadline in light of so much other activity demanding our attention. May I suggest that we try to get as many proposed edits onto the list before our November 14 call (with much thanks to those who have already done so), with the goal of dealing with them then if possible, but leaving the door open for further edits over the next couple of weeks if necessary. Finally, some ICANN groups are adjusting the scheduling of their calls to reflect the return to standard time in North America and Europe. Is this group doing so as well? If our calls stay at 1400 UTC that is now 9 am EST and 6 am for those on Pacific time. Moving to 1500 UTC would retain the pre-existing local start times, I believe. Steve Metalitz [age001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Victoria Sheckler Sent: Tuesday, October 31, 2017 5:55 PM To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>; Sara Bockey Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 17 Oct Privacy/Proxy IRT call Please note that ICANN’s work on GDPR’s on a separate track and that one thing we know almost for sure is that the adoption of rational, predictable rules for privacy/proxy will be more important post-GDPR than it ever was. So please let’s get those rules in place as expeditiously as possible. On 30-10-2017 11:32, Sara Bockey wrote: 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<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-bounces(a)icann.org><mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Caitlin Tubergen <caitlin.tubergen(a)icann.org><mailto:caitlin.tubergen@icann.org> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl(a)icann.org><mailto:gdd-gnso-ppsai-impl@icann.org> Date: Wednesday, October 25, 2017 at 4:44 AM To: "gdd-gnso-ppsai-impl(a)icann.org"<mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl(a)icann.org><mailto:gdd-gnso-ppsai-impl@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<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<mailto:caitlin.tubergen@icann.org> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl>

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RrSG comments on the current drafts.
by Theo Geurts Dec. 1, 2017

Dec. 1, 2017

Dear IRT members. Attached the comments from several RrSG members. Thank you for the comments and support and the valuable discussions: Key-Systems, Volker Greimann Netearth One, Chris Pelling Nordreg, Benny Samuelsen One.com, Rieke Poppe 1und1, Thomas Keller Astutium, Rob Golding Godaddy, Sara Bockey, thank you for assisting me with the reviews. DNS Africa, Vlad Dinculescu Best regards, Theo Geurts

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Materials, action items from 14 Nov IRT Call
by Caitlin Tubergen Nov. 16, 2017

Nov. 16, 2017

Dear Colleagues, Thanks so much for your participation on Tuesday’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/14+November+2017. On the call, the group agreed to a deadline for Friday, 1 December for all IRT members to provide feedback on the most recent draft PPAA (from 20 October). Accordingly, please use this time to review the draft and provide feedback via the list. The next IRT meeting will be Tuesday, 5 December at 1500UTC. Please let me know if you have any questions. Thank you! 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] [Ntfy-gdd-gnso-ppsai-impl] Privacy and Proxy Services Accreditation Program IRT Meeting
by theo geurts Nov. 14, 2017

Nov. 14, 2017

I won't be able to attend. Thanks, Theo Geurts On 14-11-2017 00:09, ICANN Policy Calendar wrote: > > ICANN Policy Calendar has invited you to Privacy and Proxy Services > Accreditation Program IRT Meeting > > Title: > > > > Privacy and Proxy Services Accreditation Program IRT Meeting > > Location: > > > > 15:00 UTC > > When: > > > > Tue 14 Nov 2017 16:00 – 17:30 > > > > > Organizer: > > > > ICANN Policy Calendar <PolicyCalendar(a)icann.org> > > Description: > > > > ****Due to Daylight Savings time change, we are changing the start > time to 15:00 UTC**** Dear Colleagues, Please find below the remote > participation details for the Privacy and Proxy Services Accreditation > Program IRT Meetings which will now be held WEEKLY on Tuesdays, > starting on 29 November 2016 at 15:00 UTC for 1 hour 30 minutes. Adobe > Connect link: https://participate.icann.org/ppirt Participant code: > 4824695647 Dial-In Phone Numbers: US: +1-719-457-6209 Canada, Calgary: > +1 403 407 5793 Canada, Montreal: +1 514 669 5928 Canada, Toronto: +1 > 647 426 9172 Canada, Vancouver: +1 604 222 7836 Argentina (toll free): > 0800 800 1223 Argentina, Buenos Aires: +54 (0) 11 5172 6003 Australia > (toll free): 1 800 804 786 Australia, Brisbane: +61 (0) 7 3015 0535 > Australia, Melbourne: +61 (0) 3 8687 0553 Australia, Sydney: +61 (0) 2 > 8017 6064 Austria (toll free): 0800 8866 3413 Austria, Vienna: +43 (0) > 1 25302 1785 Bahrain (toll free): 800 04212 Bahrain, Manama: +973 1619 > 8739 Belarus (toll free): 8 820 0011 0341 Belgium (toll free): 0800 > 39279 Belgium, Brussels: +32 (0) 2 400 6928 Brazil (toll free): 0800 > 887 0233 Brazil, Rio de Janeiro: +55 21 4560 0072 Brazil, Sao Paulo: > +55 11 4935 7169 Bulgaria (toll free): 00800 111 4950 Bulgaria, Sofia: > +359 (0) 2 491 6045 Canada (toll free): 1 855 950 3717 Chile (toll > free): 171 800 835 783 Chile, Santiago: +56 (0) 2 2666 0696 China > (national): +400 613 8103 China, Beijing: +86 10 5667 0003 China, > Shanghai: +86 21 2039 7081 Colombia (toll free): 01 800 755 0102 > Colombia, Bogota: +57 1 508 8137 Croatia (toll free): 0800 805 940 > Cyprus (toll free): 800 97424 Czech Republic (toll free): 800 701 532 > Czech Republic, Prague: +420 225 986 554 Denmark (toll free): 80 70 35 > 86 Denmark, Copenhagen: +45 32 72 78 10 Egypt (toll free): 0800 000 > 0593 Estonia (toll free): 800 011 1589 Estonia, Tallinn: +372 622 6551 > Fiji (toll free): 00800 3322 Finland (toll free): 0800 772 236 > Finland, Helsinki: +358 (0) 9 2310 1677 France (national): 0811 655 > 100 France (toll free): 0800 946 531 France, Paris: +33 (0) 1 70 37 16 > 56 Germany (national): 01801 003 899 Germany (toll free): 0800 588 > 9170 Germany, Frankfurt: +49 (0) 69 2222 10612 Germany, Munich: +49 > (0) 89 2030 31207 Greece (toll free): 00800 128 913 Greece, Athens: > +30 211 181 3824 Hong Kong: +852 3018 9111 Hong Kong (toll free): 800 > 901 787 Hungary (toll free): 068 001 9673 Hungary, Budapest: +36 1408 > 8953 Iceland (toll free): 800 9847 India, Bangalore: +91 (0) 80 6127 > 6710 India, Chennai: +91 (0)44 6688 6061 India, Delhi: +91 (0) 11 6641 > 1394 India, Mumbai: +91 (0)22 6187 5028 Indonesia (toll free): 007 803 > 321 8927 Ireland (national): 1890 907 630 Ireland (toll free): 1800 > 937 649 Ireland, Dublin: +353 (0) 1 526 9421 Israel (toll free): 1809 > 213 168 Israel, Tel Aviv: +972 (0)3 721 7943 Italy (toll free): 800 > 146 094 Italy, Milan: +39 02 3600 8006 Italy, Rome: +39 06 8750 0676 > Japan (mobile): 0120 632 611 Japan (toll free): 0120 305 211 Japan, > Osaka: +81 (0) 6 4560 2410 Japan, Tokyo: +81 (0) 3 4560 1270 > Kazakhstan (toll free): 8800 333 7554 Latvia (toll free): 8000 4418 > Latvia, Riga: +371 6601 3627 Lithuania (toll free): 8800 31449 > Lithuania, Vilnius: +370 5205 5468 Luxembourg: +352 2088 1749 > Luxembourg (toll free): 800 28433 Malaysia (toll free): 1 800 816 152 > Malaysia,Kuala Lumpur: +60 (0) 3 7724 8010 Mexico (toll free): 01 800 > 733 4102 Mexico, Guadalajara: +52 33 4162 4504 Mexico, Mexico City: > +52 55 8421 0326 Mexico, Monterrey: +52 81 4162 5648 Morocco (toll > free): 0800 091 296 Morocco, Casablanca: +212 (0) 520 48 0022 > Netherlands (toll free): 0800 020 2597 Netherlands, Amsterdam: +31 (0) > 20 716 8345 New Zealand (toll free): 0800 452 947 New Zealand, > Auckland: +64 (0) 9 929 1825 New Zealand, Christchurch: +64 (0) 3 974 > 2596 New Zealand, Wellington: +64 (0) 4 909 4674 Nigeria, Lagos: +234 > 1 277 3944 Norway (toll free): 800 56081 Norway, Oslo: +47 21 00 48 15 > Panama (toll free): 00800 223 1390 Panama, Panama City: +507 8 335 913 > Peru, Lima: +51 (0) 1 700 9571 Philippines (toll free): 1 800 111 013 > 99 Philippines, Manila: +63 (0)2 395 3426 Poland (toll free): 00 800 > 121 4356 Poland, Warsaw: +48 22 295 3570 Portugal (toll free): 800 784 > 442 Portugal, Lisbon: +351 21 316 4093 Qatar (toll free): 00 800 100 > 491 Romania (toll free): 0800 801 035 Romania, Bucharest: +40 (0) 21 > 529 3992 Russia (toll free): 8 800 500 9241 Russia, Moscow: +7 495 646 > 9181 Saudi Arabia (toll free): 800 844 6641 Saudi Arabia (toll free): > 800 850 0219 Singapore: +65 6622 1957 Singapore (toll free): 800 616 > 3192 Slovakia (toll free): 0800 002 002 Slovakia, Bratislava: +421 > (0)2 3321 5498 Slovenia (toll free): 0800 81193 Slovenia, Ljubljana: > +386 1600 8695 South Africa (toll free): 0800 999 434 South Africa, > Johannesburg: +27 (0)11 589 8321 South Korea (toll free): 00798 6136 > 1454 South Korea, Seoul: +82 (0) 2 6007 0079 Spain (toll free): 900 > 828 035 Spain, Barcelona: +34 93 800 1946 Spain, Madrid: +34 91 114 > 6653 Sweden (toll free): 0200 125 588 Sweden, Stockholm: +46 (0) 8 > 5065 3956 Switzerland (toll free): 0800 740 360 Switzerland, Geneva: > +41 (0) 22 595 4795 Switzerland, Zurich: +41 (0) 44 580 7207 Taiwan > (toll free): 0800 666 596 Taiwan, Taipei: +886 (0) 2 2650 7329 > Thailand (toll free): 001 800 6136 1473 Turkey (toll free): 00800 4488 > 26642 Turkey, Istanbul: +90 212 375 50 49 UAE (toll free): 8000 3570 > 2662 UK (03): +44 (0)330 336 6002 UK (toll free): 0800 358 6385 > Ukraine (toll free): 0800 500 896 Uruguay (toll free): 0004 019 0152 > USA /Canada (toll free): 1-866-398-2885 Venezuela (toll free): 0 800 > 162 7451 Vietnam (toll free): 1800 9226 Costa Rica (toll free): 800 > 542 5328 France (national): 0821 231 671 India (toll free): 1800 200 > 9415 Indonesia, Jakarta: +62 21 2188 9084 Ireland (national): 0818 270 > 271 Japan (national): 0570 085 744 Serbia (toll free): 0800 190 712 UK > (national): 0844 473 5010 UK (national): 0845 545 0015 Venezuela, > Caracas: +58 212 720 2164 > > Attachments: > > > > Comment: > > > > Attendees: > > > > > ntfy-gdd-gnso-ppsai-impl(a)icann.org <ntfy-gdd-gnso-ppsai-impl(a)icann.org> > > Amy Bivins <amy.bivins(a)icann.org> > > pp_imp_staff(a)icann.org <pp_imp_staff(a)icann.org> > > Owen Smigelski <owen.smigelski(a)icann.org> > > Graeme Bunton <graemeb(a)gmail.com> > > Russ Weinstein <russ.weinstein(a)icann.org> > > Related Link: > > > > > > _______________________________________________ > Ntfy-gdd-gnso-ppsai-impl mailing list > Ntfy-gdd-gnso-ppsai-impl(a)icann.org > https://mm.icann.org/mailman/listinfo/ntfy-gdd-gnso-ppsai-impl

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Review SPECIFICATION 2: CUSTOMER DATA ACCURACY PROGRAM SPECIFICATION
by theo geurts Nov. 14, 2017

Nov. 14, 2017

Hi all, A question to the IRT and staff. SPECIFICATION 2: CUSTOMER DATA ACCURACY PROGRAM SPECIFICATION I think I understand most of the requirements here. What am I not sure of, as it is fuzzy, what is a provider supposed to do when Registrant activates a privacy service for a domain name that is*already* registered, has*not *been transferred and has *not* received updates? Currently, I think the language says the provider shall do *nothing* except turning on the privacy service. Do we agree this is how it should work? Thanks, Theo Geurts Below the current language in the agreement. Except as provided for in Section 3 below, within fifteen (15) days of (i) the registration of a Registered Name for which Provider is providing the Services, (ii) the transfer of the sponsorship of a Registered Name for which Provider is providing the Services, or (iii) any change in the Customer information associated with a Registered Name for which Provider is providing the Services, Provider will, with respect to the Customer account holder contact information related to such Registered Name:

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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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REMINDER: CALL in 10 MIN: Meeting Info for Privacy and Proxy Services Implementation Review Team
by Caitlin Tubergen Oct. 3, 2017

Oct. 3, 2017

Dear Colleagues, Please find below the remote participation details for the Privacy and Proxy Services Accreditation Program IRT Meetings will be held on Tuesday, 3 October 2017 at 14:00 UTC for 1 hour 30 minutes. Adobe Connect link: https://participate.icann.org/ppirt Participant code: 4824695647 Dial-In Phone Numbers: US: +1-719-457-6209 Canada, Calgary: +1 403 407 5793 Canada, Montreal: +1 514 669 5928 Canada, Toronto: +1 647 426 9172 Canada, Vancouver: +1 604 222 7836 Argentina (toll free): 0800 800 1223 Argentina, Buenos Aires: +54 (0) 11 5172 6003 Australia (toll free): 1 800 804 786 Australia, Brisbane: +61 (0) 7 3015 0535 Australia, Melbourne: +61 (0) 3 8687 0553 Australia, Sydney: +61 (0) 2 8017 6064 Austria (toll free): 0800 8866 3413 Austria, Vienna: +43 (0) 1 25302 1785 Bahrain (toll free): 800 04212 Bahrain, Manama: +973 1619 8739 Belarus (toll free): 8 820 0011 0341 Belgium (toll free): 0800 39279 Belgium, Brussels: +32 (0) 2 400 6928 Brazil (toll free): 0800 887 0233 Brazil, Rio de Janeiro: +55 21 4560 0072 Brazil, Sao Paulo: +55 11 4935 7169 Bulgaria (toll free): 00800 111 4950 Bulgaria, Sofia: +359 (0) 2 491 6045 Canada (toll free): 1 855 950 3717 Chile (toll free): 171 800 835 783 Chile, Santiago: +56 (0) 2 2666 0696 China (national): +400 613 8103 China, Beijing: +86 10 5667 0003 China, Shanghai: +86 21 2039 7081 Colombia (toll free): 01 800 755 0102 Colombia, Bogota: +57 1 508 8137 Croatia (toll free): 0800 805 940 Cyprus (toll free): 800 97424 Czech Republic (toll free): 800 701 532 Czech Republic, Prague: +420 225 986 554 Denmark (toll free): 80 70 35 86 Denmark, Copenhagen: +45 32 72 78 10 Egypt (toll free): 0800 000 0593 Estonia (toll free): 800 011 1589 Estonia, Tallinn: +372 622 6551 Fiji (toll free): 00800 3322 Finland (toll free): 0800 772 236 Finland, Helsinki: +358 (0) 9 2310 1677 France (national): 0811 655 100 France (toll free): 0800 946 531 France, Paris: +33 (0) 1 70 37 16 56 Germany (national): 01801 003 899 Germany (toll free): 0800 588 9170 Germany, Frankfurt: +49 (0) 69 2222 10612 Germany, Munich: +49 (0) 89 2030 31207 Greece (toll free): 00800 128 913 Greece, Athens: +30 211 181 3824 Hong Kong: +852 3018 9111 Hong Kong (toll free): 800 901 787 Hungary (toll free): 068 001 9673 Hungary, Budapest: +36 1408 8953 Iceland (toll free): 800 9847 India, Bangalore: +91 (0) 80 6127 6710 India, Chennai: +91 (0)44 6688 6061 India, Delhi: +91 (0) 11 6641 1394 India, Mumbai: +91 (0)22 6187 5028 Indonesia (toll free): 007 803 321 8927 Ireland (national): 1890 907 630 Ireland (toll free): 1800 937 649 Ireland, Dublin: +353 (0) 1 526 9421 Israel (toll free): 1809 213 168 Israel, Tel Aviv: +972 (0)3 721 7943 Italy (toll free): 800 146 094 Italy, Milan: +39 02 3600 8006 Italy, Rome: +39 06 8750 0676 Japan (mobile): 0120 632 611 Japan (toll free): 0120 305 211 Japan, Osaka: +81 (0) 6 4560 2410 Japan, Tokyo: +81 (0) 3 4560 1270 Kazakhstan (toll free): 8800 333 7554 Latvia (toll free): 8000 4418 Latvia, Riga: +371 6601 3627 Lithuania (toll free): 8800 31449 Lithuania, Vilnius: +370 5205 5468 Luxembourg: +352 2088 1749 Luxembourg (toll free): 800 28433 Malaysia (toll free): 1 800 816 152 Malaysia,Kuala Lumpur: +60 (0) 3 7724 8010 Mexico (toll free): 01 800 733 4102 Mexico, Guadalajara: +52 33 4162 4504 Mexico, Mexico City: +52 55 8421 0326 Mexico, Monterrey: +52 81 4162 5648 Morocco (toll free): 0800 091 296 Morocco, Casablanca: +212 (0) 520 48 0022 Netherlands (toll free): 0800 020 2597 Netherlands, Amsterdam: +31 (0) 20 716 8345 New Zealand (toll free): 0800 452 947 New Zealand, Auckland: +64 (0) 9 929 1825 New Zealand, Christchurch: +64 (0) 3 974 2596 New Zealand, Wellington: +64 (0) 4 909 4674 Nigeria, Lagos: +234 1 277 3944 Norway (toll free): 800 56081 Norway, Oslo: +47 21 00 48 15 Panama (toll free): 00800 223 1390 Panama, Panama City: +507 8 335 913 Peru, Lima: +51 (0) 1 700 9571 Philippines (toll free): 1 800 111 013 99 Philippines, Manila: +63 (0)2 395 3426 Poland (toll free): 00 800 121 4356 Poland, Warsaw: +48 22 295 3570 Portugal (toll free): 800 784 442 Portugal, Lisbon: +351 21 316 4093 Qatar (toll free): 00 800 100 491 Romania (toll free): 0800 801 035 Romania, Bucharest: +40 (0) 21 529 3992 Russia (toll free): 8 800 500 9241 Russia, Moscow: +7 495 646 9181 Saudi Arabia (toll free): 800 844 6641 Saudi Arabia (toll free): 800 850 0219 Singapore: +65 6622 1957 Singapore (toll free): 800 616 3192 Slovakia (toll free): 0800 002 002 Slovakia, Bratislava: +421 (0)2 3321 5498 Slovenia (toll free): 0800 81193 Slovenia, Ljubljana: +386 1600 8695 South Africa (toll free): 0800 999 434 South Africa, Johannesburg: +27 (0)11 589 8321 South Korea (toll free): 00798 6136 1454 South Korea, Seoul: +82 (0) 2 6007 0079 Spain (toll free): 900 828 035 Spain, Barcelona: +34 93 800 1946 Spain, Madrid: +34 91 114 6653 Sweden (toll free): 0200 125 588 Sweden, Stockholm: +46 (0) 8 5065 3956 Switzerland (toll free): 0800 740 360 Switzerland, Geneva: +41 (0) 22 595 4795 Switzerland, Zurich: +41 (0) 44 580 7207 Taiwan (toll free): 0800 666 596 Taiwan, Taipei: +886 (0) 2 2650 7329 Thailand (toll free): 001 800 6136 1473 Turkey (toll free): 00800 4488 26642 Turkey, Istanbul: +90 212 375 50 49 UAE (toll free): 8000 3570 2662 UK (03): +44 (0)330 336 6002 UK (toll free): 0800 358 6385 Ukraine (toll free): 0800 500 896 Uruguay (toll free): 0004 019 0152 USA /Canada (toll free): 1-866-398-2885 Venezuela (toll free): 0 800 162 7451 Vietnam (toll free): 1800 9226 Costa Rica (toll free): 800 542 5328 France (national): 0821 231 671 India (toll free): 1800 200 9415 Indonesia, Jakarta: +62 21 2188 9084 Ireland (national): 0818 270 271 Japan (national): 0570 085 744 Serbia (toll free): 0800 190 712 UK (national): 0844 473 5010 UK (national): 0845 545 0015 Venezuela, Caracas: +58 212 720 2164 Thank you, Caitlin Tubergen Registrar Services and Engagement Senior Manager ICANN

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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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Re: [Gdd-gnso-ppsai-impl] Materials, Agenda for 5 Sept PP IRT Meeting
by Michele Neylon - Blacknight Sept. 4, 2017

Sept. 4, 2017

Amy et al Just browsing this quickly and I can see some serious gaps If ICANN is suspending a provider it’s due to any number of issues so relying on the same provider you’re suspending to send notices to anyone is simply not going to work. You’re probably suspending them for breaching the policies / contract etc., so I can’t imagine they’d be likely to start sending out notices at this juncture. All of the language around customer notification is linked to the provider co-operating and acting and to be frank I can’t see that happening in a lot of cases. 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 1 September 2017 at 15:46 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials, Agenda for 5 Sept PP IRT Meeting Hello, All, Attached is the first IRT discussion draft of the privacy/proxy provider suspension and de-accreditation procedure, which we will be discussing during Tuesday’s IRT meeting. Please review this document prior to our meeting on Tuesday. In addition, we plan to discuss the issue raised on-list by Sara Bockey, regarding the draft PPAA’s requirement for 24/7/365 monitoring of a provider’s abuse contact (modeled on the RAA). We are also planning to discuss next steps on data retention. As a reminder, please send any additional feedback you have regarding the issues discussed during Tuesday’s meeting to the list this week. 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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Materials, Agenda for 5 Sept PP IRT Meeting
by Amy Bivins Sept. 1, 2017

Sept. 1, 2017

Hello, All, Attached is the first IRT discussion draft of the privacy/proxy provider suspension and de-accreditation procedure, which we will be discussing during Tuesday's IRT meeting. Please review this document prior to our meeting on Tuesday. In addition, we plan to discuss the issue raised on-list by Sara Bockey, regarding the draft PPAA's requirement for 24/7/365 monitoring of a provider's abuse contact (modeled on the RAA). We are also planning to discuss next steps on data retention. As a reminder, please send any additional feedback you have regarding the issues discussed during Tuesday's meeting to the list this week. 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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Answer to Compliance-related question raised on Tuesday's IRT call
by Amy Bivins Aug. 31, 2017

Aug. 31, 2017

Hello, All, A question was raised on Tuesday's Privacy/Proxy IRT call about the auditing of PP data in registrar data escrow deposits (is there a check to conform that registrations listed as privacy-protected are included in the data escrow deposit, i.e., a completeness check?). I checked with the Compliance team and have a bit more information to share with you. Section 2.5 of the RAA Specification on Privacy and Proxy Registrations requires registrars to include P/P Customer contact information in Registration Data Escrow deposits, and the Registrar Data Escrow Specifications does allow for registrars to escrow both sets of data; but, there is nothing built into the existing DEA agreements that requires the DEA to follow a specific audit process that is unique to privacy and proxy registrations. The DEA does follow-up with registrars to fix any issues when there are audit failures due to discrepancies in data, and sometimes, these could be due to failure of registrars to escrow both sets of data. In the recent RFP that was published to identify one or more additional ICANN designated Registrar Data Escrow (RDE) agent(s), one of the requirements is that the proposals should account for privacy and proxy registration escrow requirements, https://www.icann.org/en/system/files/files/rfp-icann-agent-rde-services-17… I hope this helps, but please let me know if you have any other clarifying questions/concerns. 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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Notes, action items from today's Privacy/Proxy IRT call
by Amy Bivins Aug. 30, 2017

Aug. 30, 2017

Hi All, Thanks for your attendance and participation on today's Privacy/Proxy IRT call. If you couldn't attend, I encourage you to listen to the recording, which is available on the wiki, https://community.icann.org/display/IRT. We have several updates and action items today. Please review this list carefully. 1. Last week's IRT poll re: PSWG-proposed edit to PP disclosure framework. The poll results, attached as JPG screenshots, are similar to the feedback received on last week's IRT call. A few IRT members supported the adoption of the PSWG proposal, but most IRT members expressed a preference to keep the language in the current PPAA draft as-is. We have sent these results to the PSWG and asked whether the PSWG would like to discuss potential compromises any further. We'll determine next steps after hearing back from the PSWG. 2. The PPAA issues list (attached) has been updated to reflect all IRT input received on the list over the past week and today's IRT call. 3. Data Escrow: Any additional feedback on the issues raised on today's call should be sent to the list no later than this Friday, 1 September. In particular, please consider whether the proposed elements of the specification that Francisco presented seem to be going in the intended direction, or whether you believe changes are needed. 4. RDDS Labeling: Any additional feedback on the issues raised on today's call should be sent to the list no later than this Friday, 1 September. 5. Agenda for 5 Sept IRT call: De-accreditation process proposal (to be sent to the list this week); PPAA issue 26 (new! Suggested on-list by Sara Bockey, re 24/7 monitoring of abuse contact); next steps on data retention (possible) 6. Any IRT feedback on comments from list from Margie Milam re: IP framework (attached) should be sent to list no later than this Friday, 1 September. 7. Any IRT feedback on comments from list from Steve Metalitz on PPAA Sect. 3.5.4 should be sent to list no later than this Friday, 1 September. 8. Please note that draft PPAA_17July (attached) has not been updated to reflect IRT discussions to date (this is the original sent to the IRT). Once we have completed the issues list, we will distribute an updated draft v2 that reflects all changes made per the IRT's feedback, for the IRT's review. Finally, as many of you are probably aware, I am preparing to go out on maternity leave in about 3 weeks (for 12 weeks). I should be around through 22 Sept, but I wanted to alert you to this in case I'm unexpectedly out before then. Caitlin Tubergen will be providing backup support for this project while I'm away (thanks, Caitlin!), and every effort has been made to keep this project moving at the current pace in my absence. Thanks to all your hard work and dedication, this IRT's work should be ready to publish for public comment while I'm away, barring any unexpected developments. I'll be following your work while I'm out, and will be back either the week before the ICANN holiday break or the first week of 2018. Thanks for your understanding and please don't hesitate to contact me if you have questions. 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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Off-List Re: Notes, action items from today's Privacy/Proxy IRT call
by Pam Little Aug. 29, 2017

Aug. 29, 2017

Hi Amy I have not been able to join these calls due to time zone issue (the meeting time is midnight in Sydney) but try to keep an eye on the developments. Thank you for the "notice" on your maternality leave. I thought that was very considerate of you and I hope everything goes well. All the best to you and your family! Kind regards, Pam ------------------------------------------------------------------From:Amy Bivins <amy.bivins(a)icann.org>Time:2017 Aug 30 (Wed) 02:12To:gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl(a)icann.org>; Caitlin Tubergen <caitlin.tubergen(a)icann.org>Subject:[Gdd-gnso-ppsai-impl] Notes, 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 couldn’t attend, I encourage you to listen to the recording, which is available on the wiki, https://community.icann.org/display/IRT. We have several updates and action items today. Please review this list carefully. Last week’s IRT poll re: PSWG-proposed edit to PP disclosure framework. The poll results, attached as JPG screenshots, are similar to the feedback received on last week’s IRT call. A few IRT members supported the adoption of the PSWG proposal, but most IRT members expressed a preference to keep the language in the current PPAA draft as-is. We have sent these results to the PSWG and asked whether the PSWG would like to discuss potential compromises any further. We’ll determine next steps after hearing back from the PSWG.The PPAA issues list (attached) has been updated to reflect all IRT input received on the list over the past week and today’s IRT call.Data Escrow: Any additional feedback on the issues raised on today’s call should be sent to the list no later than this Friday, 1 September. In particular, please consider whether the proposed elements of the specification that Francisco presented seem to be going in the intended direction, or whether you believe changes are needed.RDDS Labeling: Any additional feedback on the issues raised on today’s call should be sent to the list no later than this Friday, 1 September. Agenda for 5 Sept IRT call: De-accreditation process proposal (to be sent to the list this week); PPAA issue 26 (new! Suggested on-list by Sara Bockey, re 24/7 monitoring of abuse contact); next steps on data retention (possible)Any IRT feedback on comments from list from Margie Milam re: IP framework (attached) should be sent to list no later than this Friday, 1 September.Any IRT feedback on comments from list from Steve Metalitz on PPAA Sect. 3.5.4 should be sent to list no later than this Friday, 1 September. Please note that draft PPAA_17July (attached) has not been updated to reflect IRT discussions to date (this is the original sent to the IRT). Once we have completed the issues list, we will distribute an updated draft v2 that reflects all changes made per the IRT’s feedback, for the IRT’s review. Finally, as many of you are probably aware, I am preparing to go out on maternity leave in about 3 weeks (for 12 weeks). I should be around through 22 Sept, but I wanted to alert you to this in case I’m unexpectedly out before then. Caitlin Tubergen will be providing backup support for this project while I’m away (thanks, Caitlin!), and every effort has been made to keep this project moving at the current pace in my absence. Thanks to all your hard work and dedication, this IRT’s work should be ready to publish for public comment while I’m away, barring any unexpected developments. I’ll be following your work while I’m out, and will be back either the week before the ICANN holiday break or the first week of 2018. Thanks for your understanding and please don’t hesitate to contact me if you have questions. Best,Amy Amy E. BivinsRegistrar Services and Engagement Senior ManagerRegistrar Services and Industry RelationsInternet Corporation for Assigned Names and Numbers (ICANN)Direct: +1 (202) 249-7551Fax: +1 (202) 789-0104Email: amy.bivins(a)icann.orgwww.icann.org

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Re: [Gdd-gnso-ppsai-impl] Notes, Action Items from 22 August PP IRT Call [PLEASE complete poll]
by Darcy Southwell Aug. 29, 2017

Aug. 29, 2017

My apologies, but I won’t be able to make today’s meeting. Best, Darcy ---------------- Darcy Southwell | Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart 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> Date: Wednesday, August 23, 2017 at 7:00 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 22 August PP IRT Call [PLEASE complete poll] Hello, All, Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. For those of you would could not attend, I encourage you to please listen to the recording, available on the wiki, https://community.icann.org/display/IRT/22+August+2017. Several action items resulted from this meeting: IRT: Please complete this linked poll regarding the proposed edit to the LEA framework, specification 4 of the draft PPAA, https://www.surveymonkey.com/r/2F5BGBG, no later than next Monday, 28 August. Please read the background before the first question carefully. The IRT discussion on this topic yesterday continued to demonstrate a division among the group regarding this proposed edit. The results of this poll will not be counted as a vote but are intended to ensure that we have a complete record and understanding of all IRT participants’ opinions on this topic. This is important. Please participate. There are only two substantive questions. IRT: Please provide any additional feedback no later than Monday, 28 August, on the “record-keeping” topic, issue 24 on the issues list. IRT: Please provide any additional feedback you have no later than Monday, 28 August, on the IP framework (issue 20 on the issues list), particularly the issue raised on the call, regarding the proposed addition of language from the framework’s introduction in the Final Report. IRT: Please provide any additional feedback you have no later than Monday, 28 August, on the “business dealings” section of the PPAA draft (issue 25 on the issues list). ICANN will review the “business dealings” section of the PPAA draft, per IRT feedback, to ensure that the language (when read in consultation with the rest of the contract) will not result in duplicative notice requirements (ie, customers should receive one notice (e.g. data accuracy notices), either from the provider or registrar—not both). Finally, you will notice that we are moving fairly quickly to the end of the issues list (albeit with many action items to follow up on). Please send any additional points related to the PPAA draft that you would like to discuss to the list. Once we reach the end of the issues list, if we have no further suggestions from you, we will move on to other topics. For next week’s call, we are planning to discuss data escrow and RDDS labeling. I will confirm this by Monday morning Eastern Time at the latest (we are currently working to finalize an updated draft specification for your review). 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 www.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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Notes, Action Items from 22 August PP IRT Call [PLEASE complete poll]
by Amy Bivins Aug. 29, 2017

Aug. 29, 2017

Hello, All, Thanks so much for your active participation on yesterday's Privacy/Proxy IRT call. For those of you would could not attend, I encourage you to please listen to the recording, available on the wiki, https://community.icann.org/display/IRT/22+August+2017. Several action items resulted from this meeting: * IRT: Please complete this linked poll regarding the proposed edit to the LEA framework, specification 4 of the draft PPAA, https://www.surveymonkey.com/r/2F5BGBG, no later than next Monday, 28 August. Please read the background before the first question carefully. * The IRT discussion on this topic yesterday continued to demonstrate a division among the group regarding this proposed edit. The results of this poll will not be counted as a vote but are intended to ensure that we have a complete record and understanding of all IRT participants' opinions on this topic. This is important. Please participate. There are only two substantive questions. * IRT: Please provide any additional feedback no later than Monday, 28 August, on the "record-keeping" topic, issue 24 on the issues list. * IRT: Please provide any additional feedback you have no later than Monday, 28 August, on the IP framework (issue 20 on the issues list), particularly the issue raised on the call, regarding the proposed addition of language from the framework's introduction in the Final Report. * IRT: Please provide any additional feedback you have no later than Monday, 28 August, on the "business dealings" section of the PPAA draft (issue 25 on the issues list). * ICANN will review the "business dealings" section of the PPAA draft, per IRT feedback, to ensure that the language (when read in consultation with the rest of the contract) will not result in duplicative notice requirements (ie, customers should receive one notice (e.g. data accuracy notices), either from the provider or registrar-not both). Finally, you will notice that we are moving fairly quickly to the end of the issues list (albeit with many action items to follow up on). Please send any additional points related to the PPAA draft that you would like to discuss to the list. Once we reach the end of the issues list, if we have no further suggestions from you, we will move on to other topics. For next week's call, we are planning to discuss data escrow and RDDS labeling. I will confirm this by Monday morning Eastern Time at the latest (we are currently working to finalize an updated draft specification for your review). 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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Action items from today's PP IRT call
by Amy Bivins Aug. 22, 2017

Aug. 22, 2017

Hello, All, Thanks so much for your participation on today's IRT call. I've updated the issues list (attached) with the input we received on this morning's call. We have several outstanding discussion topics that we are requesting your feedback on via the list this week (requested deadline of 21 August): 1. Any additional feedback on PPAA issue 1: definitions (outlined in detail in attached slides from this week's meeting) 1. Any additional feedback on PPAA issue 3: amendment/negotiation process. Edits were proposed by ICANN this week to allow proposed amendments to the PPAA to be considered by a working group convened by the GNSO or the Privacy/Proxy Stakeholder Group (if one is ever created). During today's call, it was recommended by an IRT member that this should be limited, such that if there is ever a stakeholder group, its members can participate in the GNSO-convened group, but would not replace the GNSO-convened group in the PPAA amendment negotiation process. For reference, for the RAA negotiation process, the "working group" for negotiations is convened by the RrSG (See 2013 RAA Section 7.4.1). IRT feedback is requested on the proposed edits as well as the recommendation raised on today's call. 1. Any additional feedback on PPAA issue 21: RAA synchronization. The IRT was asked whether any future updates to the RAA involving sections that are adapted in the PPAA should result in automatic updates to the PPAA. It was recommended on today's call that updates could be synchronized with the PPAA, but this should not be automatic. Any proposed updates to the PPAA as a result of RAA updates should be presented to the working group (referenced in Item 2, above) for approval. IRT feedback is sought on the topic of synchronization in general, as well as the recommendation made on today's call. In addition, feedback is sought on whether, if we do decide to have an approval mechanism before changes go into effect, the working group should always be the approval mechanism or whether other means, such as a public comment forum, could also be used. 1. Leading into next week's continued discussion of the LEA framework, additional IRT feedback is requested on the proposed edit from the PSWG, that would reduce the time to review requests from LEA from 2 business days to 24 hours (See PPAA Issue 19 in attached issues list). IRT feedback on this topic has not produced a clear consensus on this topic. Please consider this issue and come prepared to discuss this topic on next week's call, with the goal of reaching a resolution on this topic. 1. Customer Data Accuracy (See item 15 in issues list). It was noted on-list and on today's call that the requirements in the draft Customer Data Accuracy Specification and Section 3.5.4.1, including pending updates based on IRT input, may result in some inconsistencies or lack of clarity surrounding requirements for providers. Please provide any further input on this topic. ICANN will revisit these provisions, taking into account IRT feedback, and propose language to clarify these requirements. Thanks so much in advance for your consideration of these items. For next week's call, we are planning to discuss: * The PSWG-proposed update to the LEA framework, * Proposed next steps on data retention based on IRT feedback, * The IP framework, * ICANN reporting requirements, and * Any IRT feedback on the "business dealings" section of the PPAA (section 3.5)(this was a topic suggested by an IRT member). If you have questions or comments in the interim, please don't hesitate to send them 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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Re: [Gdd-gnso-ppsai-impl] Action items from today's PP IRT call
by Margie Milam Aug. 22, 2017

Aug. 22, 2017

Hi- In advance of tomorrow’s call, here are a few issues to consider related to the IP related text: * The Final Report states: Given the balance that this Policy attempts to strike, evidence of the use of high-volume, automated electronic processes for sending Requests or responses to Requests (without human review) to the systems of Requesters, Providers, or Customers in performing any of the steps in the processes outlined in this Policy shall create a rebuttable presumption of non-compliance with this Policy. I may have missed this, but it seems the Agreement should include an obligation on the Provider to conduct a human review of the requests. Also, is there language regarding the rebuttable presumption of noncompliance if there are high-volume automated electronic responses to a request? * How does the IP requester know where to send the requests or that the domain name is a privacy/proxy registration? Specification 3 doesn’t seem to include a unique label for P/P Providers nor does it include the Abuse Point of Contact information for the Provider. 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: Tuesday, August 15, 2017 at 12:40 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Action items from today's PP IRT call Hello, All, Thanks so much for your participation on today’s IRT call. I’ve updated the issues list (attached) with the input we received on this morning’s call. We have several outstanding discussion topics that we are requesting your feedback on via the list this week (requested deadline of 21 August): 1. Any additional feedback on PPAA issue 1: definitions (outlined in detail in attached slides from this week’s meeting) 1. Any additional feedback on PPAA issue 3: amendment/negotiation process. Edits were proposed by ICANN this week to allow proposed amendments to the PPAA to be considered by a working group convened by the GNSO or the Privacy/Proxy Stakeholder Group (if one is ever created). During today’s call, it was recommended by an IRT member that this should be limited, such that if there is ever a stakeholder group, its members can participate in the GNSO-convened group, but would not replace the GNSO-convened group in the PPAA amendment negotiation process. For reference, for the RAA negotiation process, the “working group” for negotiations is convened by the RrSG (See 2013 RAA Section 7.4.1). IRT feedback is requested on the proposed edits as well as the recommendation raised on today’s call. 1. Any additional feedback on PPAA issue 21: RAA synchronization. The IRT was asked whether any future updates to the RAA involving sections that are adapted in the PPAA should result in automatic updates to the PPAA. It was recommended on today’s call that updates could be synchronized with the PPAA, but this should not be automatic. Any proposed updates to the PPAA as a result of RAA updates should be presented to the working group (referenced in Item 2, above) for approval. IRT feedback is sought on the topic of synchronization in general, as well as the recommendation made on today’s call. In addition, feedback is sought on whether, if we do decide to have an approval mechanism before changes go into effect, the working group should always be the approval mechanism or whether other means, such as a public comment forum, could also be used. 1. Leading into next week’s continued discussion of the LEA framework, additional IRT feedback is requested on the proposed edit from the PSWG, that would reduce the time to review requests from LEA from 2 business days to 24 hours (See PPAA Issue 19 in attached issues list). IRT feedback on this topic has not produced a clear consensus on this topic. Please consider this issue and come prepared to discuss this topic on next week’s call, with the goal of reaching a resolution on this topic. 1. Customer Data Accuracy (See item 15 in issues list). It was noted on-list and on today’s call that the requirements in the draft Customer Data Accuracy Specification and Section 3.5.4.1, including pending updates based on IRT input, may result in some inconsistencies or lack of clarity surrounding requirements for providers. Please provide any further input on this topic. ICANN will revisit these provisions, taking into account IRT feedback, and propose language to clarify these requirements. Thanks so much in advance for your consideration of these items. For next week’s call, we are planning to discuss: * The PSWG-proposed update to the LEA framework, * Proposed next steps on data retention based on IRT feedback, * The IP framework, * ICANN reporting requirements, and * Any IRT feedback on the “business dealings” section of the PPAA (section 3.5)(this was a topic suggested by an IRT member). If you have questions or comments in the interim, please don’t hesitate to send them 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<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DwMFAg&…>

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Action items, request for additional IRT input after 8 August IRT call
by Amy Bivins Aug. 15, 2017

Aug. 15, 2017

Dear Colleagues, Thanks so much for your active participation on today's IRT call. If you were unable to attend, I encourage you to listen to the recording, which is available on the wiki, https://community.icann.org/display/IRT/08+August+2017 Attached, you will find an updated "issues list" that includes a detailed summary of all the PPAA-related topics discussed to date, including those raised on the call today. A very short summary of the input received today and the significant outstanding questions is also available below. Please review the topics discussed today and submit any additional feedback you have no later than next Monday, 14 August. Your feedback is especially needed on the LEA Framework and Data Retention topics. Proposed upcoming IRT discussion schedule: 15 August: PPAA definitions, PPAA amendment/negotiation process (updated per IRT feedback), RAA synchronization, request suggestions for future discussion topics 22 August: LEA framework, data retention, IP Framework, business dealings 29 August: Data escrow, labeling (new draft specification modeled on RAA requirements to be provided, per IRT feedback) Summary of Discussion on Today's Call * PPAA Issues 18-19: LEA Framework: * Updates to definitions to conform with rest of PPAA: no further edits suggested by IRT * Proposed edit to Section 3.2.1 from PSWG, editing the section as follows: [cid:image002.png@01D3105C.76955490] * Summary of proposed edit: This would reduce the period required for a provider to initiate a review of a law enforcement request from 2 business days to 24 hours. However, this would also eliminate any requirement for the provider to respond to the LEA requester within 24 hours. * PSWG rationale: This edit was made to align more closely with RAA requirement (See Section 3.18.2<https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en> RAA-"Well-founded reports of Illegal Activity submitted to these contacts must be reviewed within 24 hours by an individual who is empowered by Registrar to take necessary and appropriate actions in response to the report." * Summary of IRT feedback thus far: Some IRT members said 24 hours is too short a period; possibly 1 business day would be preferable; Other IRT members supported edit and alignment with RAA. See issues list for detailed feedback. * PPAA Issues 4, 23: Data Retention Requirements * Summary of IRT Feedback: Proposed required data elements appear generally OK; retention period appears to create issues under global data protection laws notwithstanding proposed reduction from RAA's 2-year requirement to 1-year requirement proposed for PPAA * Proposed solution raised by IRT member: Edit to require retention based on maximum period allowed under applicable law. * PPAA Issue 12: Accreditation Agreement Term * Summary of IRT Feedback: IRT members who commented supported the inclusion of a 5-year term for the contract, as is done for the RAA. * Customer Data Accuracy Specification: * Summary of IRT Feedback: Questions raised regarding how third-party providers would comply with these requirements. * IRT is requested to comment further on this specification, specifically, if a third-party provider cannot comply with these requirements, how should this be handled in the contract? 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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Updates, action items following 1 August PP IRT call
by Amy Bivins Aug. 8, 2017

Aug. 8, 2017

Dear Colleagues, Thanks so much for your active participation on today's Privacy/Proxy IRT call. We made a lot of progress. If you were unable to attend, the recording and materials are available on the wiki, https://community.icann.org/display/IRT/01+August+2017. I've updated the issues list (attached) for the topics discussed today (Issues 5, 6, 9, 10, 13) based on your feedback. IRT Action Items 1. Please provide any additional input you have on issues 5, 6, 9, 10, and 13 no later than next Monday, 7 August. In particular, please consider the following questions that arose during today's meeting: * Regarding issue 6 (Section 3.5.4.1 of the draft PPAA), should we consider reducing the required period from 15 days to some shortened period? If yes, do you have recommendations for what the shortened time period should be? * Regarding issue 13 (PPAA section 5.7.1): (i) Is it feasible for a registrar to block new registrations from a suspended provider (provided that provider is identified by its ICANN ID during the registration process)? (IRT input on this point has been mixed); (ii) If the answer to (i) is yes, is any additional language required with respect to Point 5 raised during the call ("sounds like we need an EPP for PP Providers")? 2. Please complete the IRT poll re: data escrow and additional PPAA discussion topics no later than Friday, 4 August, https://www.surveymonkey.com/r/62XCMSS Next Week Next week, we plan to discuss Issues 4 and 23(data retention), 12 (accreditation term), 15 (Customer Data Accuracy Spec), 17-19 (LEA Specification). We will discuss data retention and the LEA specification first, to ensure we can discuss both of these while we have our PSWG colleagues on the call. Thanks in advance for your continued consideration of the issues discussed today and your completion of the poll. If you have questions or comments before our next meeting, please send them 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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Reminder--last day for IRT poll, please review topics for next week's call
by Amy Bivins Aug. 4, 2017

Aug. 4, 2017

Hello, All: I hope you are well. This is a reminder to please complete the IRT poll no later than your EOD today, https://www.surveymonkey.com/r/62XCMSS. Also, in preparation for our meeting on Tuesday, please review the following sections of the PPAA draft and related issues on the issues list: * Data Retention Specification and PPAA Section 3.2 (issues 4 and 23 on the issues list); * The LEA specification (issues 17-19 on the issues list); * Issue 12 on the issues list (re: the term of the accreditation agreement); and * The Customer Data Accuracy Specification (issue 15 on the issues list). We may not make it through all these topics, but we'll get as far as we can. If you have questions or comments on these between now and then, please share them with the list. 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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Re: [Gdd-gnso-ppsai-impl] Topics for tomorrow's PP IRT meeting
by Michelle DeSmyter Aug. 1, 2017

Aug. 1, 2017

Thank you Lindsay, We will note your apology for today's meeting. Kind regards, Michelle From: <gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Lindsay Hamilton-Reid <Lindsay.Hamilton-Reid(a)fasthosts.com<mailto:Lindsay.Hamilton-Reid@fasthosts.com>> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Date: Tuesday, August 1, 2017 at 9:42 AM To: "gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>" <gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>> Subject: Re: [Gdd-gnso-ppsai-impl] Topics for tomorrow's PP IRT meeting Hi Amy Please accept my apologies for today, I am stuck in another meeting. Many thanks Lindsay From: gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: 24 July 2017 13:17 To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Topics for tomorrow's PP IRT meeting Hello, All, At tomorrow's privacy/proxy IRT meeting (1400 UTC), we will be discussing: * The data escrow specification in the draft PPAA; and * The issues raised last week regarding the amendment process in the draft PPAA. We will do a live poll to rank the PPAA issues that have been raised to date for discussion (by staff and IRT members) so that we can create a schedule for these discussions. I hope you all can make it. I've attached an updated issues list to add the items raised on the list over the weekend. 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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Topics for tomorrow's PP IRT meeting
by Amy Bivins Aug. 1, 2017

Aug. 1, 2017

Hello, All, At tomorrow's privacy/proxy IRT meeting (1400 UTC), we will be discussing: * The data escrow specification in the draft PPAA; and * The issues raised last week regarding the amendment process in the draft PPAA. We will do a live poll to rank the PPAA issues that have been raised to date for discussion (by staff and IRT members) so that we can create a schedule for these discussions. I hope you all can make it. I've attached an updated issues list to add the items raised on the list over the weekend. 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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Action items (including poll) from today's PP IRT call
by Amy Bivins July 31, 2017

July 31, 2017

Dear Colleagues, Thank you for your active participation on today's Privacy/Proxy IRT call. I've attached an updated issues list that includes notes from our discussions today. To summarize for those who could not attend, we discussed the draft PPAA data escrow specification, amendment process, and priorities for upcoming IRT discussions regarding the agreement. To ensure we have a complete record of IRT member views surrounding the data escrow specification, we are re-polling the group. Please complete this poll no later than next Friday, 4 August. We are allowing over a week to complete this poll to ensure that all IRT members have adequate time to consider this issue and provide your input. There is only one substantive question. The results of this poll, coupled with the IRT discussions on the topic to date, will be used to determine the final IRT view on this topic. Thus, it is important that you participate if you want your opinion heard. The poll is available at https://www.surveymonkey.com/r/62XCMSS. As a reminder on the background of this provision, the Final Report does not explicitly mention data escrow, but seems to contemplate that data escrow would be an element of this accreditation program. The 2013 RAA's interim specification on privacy and proxy registration<https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#pri…>s includes data escrow requirements. IRT members in attendance at the 28 February IRT meeting and discussing the topic on-list confirmed that this program should have data escrow requirements built into it, https://community.icann.org/display/IRT/28+February+2017 The poll also asks you to identify other sections of the PPAA that you would like to discuss in detail in an upcoming IRT meeting. However, please note that any and all comments related to the PPAA draft are also welcome on the list anytime. Based on the IRT discussion and poll today, we are planning to discuss the following topics in August. Please consult the attached issues list to see specific questions related to this topic: 1 August: Provider Suspension (Issue 13); Contact Information (Issue 9); Reveal Requirements (Issue 10); Code of Conduct (Issue 5); Domain Name Cancellation (Issue 6) 8 August: LEA Framework Specification (Issues 17-19); Data Retention (Issues 4, 23) (This is pending confirmation of PSWG availability to attend this meeting) 15 August: Definitions (Issue 1); Amendment Process (Issues 2, 3, pending updates following 25 July IRT discussion); RAA Synchronization (Issue 21) 22 August: Any issues not reached above, plus additional topics recommended by IRT in poll and on-list 29 August: Data Escrow (Issue 14, pending results of IRT discussions and poll); Labeling (Issue 16) Please send any additional input on the topics discussed this week to the list prior to our next meeting. For next week, please come prepared to discuss the topics identified above under 1 August (and please feel free to share any comments with the group beforehand on-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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Agreement comments
by theo geurts July 25, 2017

July 25, 2017

Hi all, Attached my comments on the agreement. Overall the agreement is in pretty good shape. A few sections are somewhat problematic. Section 2.3 Domain Name Resolves to Website Where Trademark Is Allegedly Infringed coupled with Section 3. Provider Action on Request. Perhaps it is me, but I have this fear that these two sections will create a lot of manual labor on the Registrar/provider side? Or has the potential to create a ton of work. Again maybe it is me, some input from Registrars or WG members is very welcome. Perhaps this was the intention of the WG; I am not sure. SPECIFICATION 6: DATA RETENTION SPECIFICATION Maybe I just have grown a healthy distaste when it comes to waiver processes, but do we require a data retention spec for a privacy service? Thanks, Theo Ps, that agreement is a very long read......

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Data escrow question WAS RE: Action Items From Today's PP IRT Call
by Metalitz, Steven July 24, 2017

July 24, 2017

With the hope of jump-starting a bit the data escrow discussion that is teed up for Tuesday, let me share with the list the question I raised on this morning's brief attempted call of the subteam re unaffiliated providers. The data escrow provisions in the draft accreditation agreement are quite complex and detailed, amounting to a 5-page specification. We are told this specification is drawn from the standard gTLD registry agreement. By contrast, the data escrow obligations in the Registrar Accreditation Agreement are boiled down to a single paragraph (section 3.6). Since all the p/p providers that have engaged in the WG and in the IRT are affiliated with accredited registrars, we have sought to maximize the situations in which these providers may be able to "piggy-back" on obligations already undertaken by registrars, in order to minimize unnecessary duplication of effort. Data escrow would appear to be an excellent candidate for this treatment as well. Perhaps RAA section 3.6 could be adapted for the p/p accreditation context. (Of course, if the RAA provision is modified in the future to align more closely with the registry obligations, the p/p obligations may be able to move in lockstep with it.) Of course this is not a complete solution, we would still have to look at the obligations for unaffiliated providers, but at least for the affiliated ones this seems more efficient. So my question is, what is the downside of this approach? Put another way, what would be the advantage gained by aligning the p/p escrow obligations with those of registries, rather than those of registrars? Amy perhaps you can also pass this question on to the ICANN technical staff that will be on Tuesday's call, so that they can respond to it on this list, or if not, on Tuesday's call. Thanks all and have a good weekend. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, July 18, 2017 11:36 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: * Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached). 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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Action Items From Today's PP IRT Call
by Amy Bivins July 20, 2017

July 20, 2017

Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: * Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached). 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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Draft PPAA materials attached for tomorrow's IRT call
by Amy Bivins July 18, 2017

July 18, 2017

Dear Colleagues, Attached, you will find documents related to the IRT's review of the draft Privacy and Proxy Service Provider Accreditation Agreement. We will discuss each of these items and the process for reviewing the draft PPAA during tomorrow's IRT call, scheduled for 18 July at 1400 UTC. Please plan to attend. Please find attached: 1. Draft PPAA 2. Draft PPAA issues list 3. Draft PPAA "suggested modification" form 4. Document mapping Final Recommendations to draft PPAA and draft Policy document During tomorrow's call, we will discuss: * An overview of the draft PPAA * The planned process for IRT review of the PPAA * An overview of the PPAA issues list * The status of parallel work (subteam 3 and upcoming work related to the Transfer Policy) I look forward to speaking with you tomorrow! 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] Updated PSWG framework draft, action items from today's IRT call
by Darcy Southwell July 13, 2017

July 13, 2017

Thanks, Amy. I hope you can encourage ICANN Legal to share the draft accreditation agreement well in advance of next Tuesday’s meeting. Without being able to review it in advance, meeting participants will not be able to provide any substantive feedback or questions or engage in meaningful dialogue. Best, Darcy 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> Date: Tuesday, July 11, 2017 at 11:39 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Updated PSWG framework draft, action items from today's IRT call Hello, All, Thanks so much for your participation on the PP IRT call today. I’ve made one final edit to the draft LEA framework document per our discussion (See section 3.1). Any comments/suggestions on that section are welcome! In the update, I did not reference any specific type of contact that was discussed on the call, and left it as “designated contact.” If you think examples would be helpful to provide added clarity that the contact could be a form or any other means, please feel free to suggest line edits. I am checking with the internal team as to whether/when I can share the draft accreditation agreement prior to next week’s call, and will share any updates I can get on that as soon as possible. In the interim, if you have questions or comments, please don’t hesitate to ask. 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 www.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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Updated PSWG framework draft, action items from today's IRT call
by Amy Bivins July 12, 2017

July 12, 2017

Hello, All, Thanks so much for your participation on the PP IRT call today. I've made one final edit to the draft LEA framework document per our discussion (See section 3.1). Any comments/suggestions on that section are welcome! In the update, I did not reference any specific type of contact that was discussed on the call, and left it as "designated contact." If you think examples would be helpful to provide added clarity that the contact could be a form or any other means, please feel free to suggest line edits. I am checking with the internal team as to whether/when I can share the draft accreditation agreement prior to next week's call, and will share any updates I can get on that as soon as possible. In the interim, if you have questions or comments, please don't hesitate to ask. 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] Agenda, materials for 11 July PP IRT call
by Darcy Southwell July 11, 2017

July 11, 2017

My apologies, but I have a conflict for today’s meeting. Darcy ---------------- Darcy Southwell | Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart 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> Date: Wednesday, July 5, 2017 at 10:50 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda, materials for 11 July PP IRT call Dear Colleagues, This is a reminder that the Privacy/Proxy Service Provider Accreditation Program IRT’s next meeting is scheduled for 11 July, at 1400 UTC. Login details were distributed separately with the calendar invitation. Next week, we will continue the discussion with Nick Shorey and any other PSWG members who are in attendance regarding the draft LEA disclosure framework. A draft redline is attached—this document has been updated to reflect the group’s discussions at ICANN59. We are hoping to, at a minimum, continue discussing Section 3.1 (the designated LEA contact, and options for how a provider could share that contact with the relevant authorities without publishing it on the provider’s website) and Section 3.2.1, regarding the IRT’s proposal to extend the time for a Provider to review each law enforcement request from 24 hours (proposed by the PSWG) to 2 business days in the Provider’s jurisdiction. To the extent there is remaining time, we can also discuss any other topics you would like to raise with the PSWG regarding this proposal. I hope you all can make it! If you have comments, please don’t hesitate to bring them up on the list before the call. 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 www.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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Agenda, materials for 11 July PP IRT call
by Amy Bivins July 5, 2017

July 5, 2017

Dear Colleagues, This is a reminder that the Privacy/Proxy Service Provider Accreditation Program IRT's next meeting is scheduled for 11 July, at 1400 UTC. Login details were distributed separately with the calendar invitation. Next week, we will continue the discussion with Nick Shorey and any other PSWG members who are in attendance regarding the draft LEA disclosure framework. A draft redline is attached-this document has been updated to reflect the group's discussions at ICANN59. We are hoping to, at a minimum, continue discussing Section 3.1 (the designated LEA contact, and options for how a provider could share that contact with the relevant authorities without publishing it on the provider's website) and Section 3.2.1, regarding the IRT's proposal to extend the time for a Provider to review each law enforcement request from 24 hours (proposed by the PSWG) to 2 business days in the Provider's jurisdiction. To the extent there is remaining time, we can also discuss any other topics you would like to raise with the PSWG regarding this proposal. I hope you all can make it! If you have comments, please don't hesitate to bring them up on the list before the call. 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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Canceled: Canceled due to low attendance: PP IRT/PSWG discussion
by Amy Bivins June 28, 2017

June 28, 2017

Dear Colleagues, We are canceling the PP IRT/PSWG meeting scheduled for Thursday morning, 9am J'burg time, due to a low number of RSVPs. I'm sorry for any inconvenience. Please watch your inboxes for details about rescheduling this discussion at a later date. Safe travels to all those who will be traveling home from ICANN59. Best, Amy

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Please accept invite or respond if planning to attend: PP IRT/PSWG discussion
by Amy Bivins June 28, 2017

June 28, 2017

Hello All, As we have a relatively low number of RSVPs for this meeting right now, we may need to cancel this meeting. If you are planning to attend, please accept this invite no later than midnight, J'burg time. If we don't have a broad list of IRT members who plan to attend, we will cancel and follow up with a Doodle poll to try to schedule some time to discuss with the PSWG next week (this will be on a day other than the regular meeting day, since that is a holiday in the US). Thanks so much, Amy -----Original Appointment----- From: Amy Bivins [mailto:amy.bivins@icann.org] Sent: Wednesday, June 28, 2017 10:48 AM To: lists(a)nickshorey.com; gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] PP IRT/PSWG discussion When: Thursday, June 29, 2017 3:00 AM-4:00 AM (UTC-05:00) Eastern Time (US & Canada). Where: ICANN59 - Pavilion S8 Dear Colleagues, We found space available for a continuation of the IRT/PSWG discussion from Monday, if you are able to attend. Remote participation will not be available in this room, but detailed notes will be shared with the full IRT and PSWG following this meeting, and posted on the public wiki. IRT members, please let me know if you are in J'burg and able to attend, as we should cancel if we can't get several people in the room. Best, Amy

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Re: [Gdd-gnso-ppsai-impl] PP IRT/PSWG discussion
by Amy Bivins June 28, 2017

June 28, 2017

So sorry, everyone-I was trying to send this to Greg and not the whole list when I forwarded the congratulations. (Huge apology to you, Greg). -----Original Appointment----- From: Amy Bivins Sent: Wednesday, June 28, 2017 2:21 PM To: Roger D Carney; Eric Rokobauer; lists(a)nickshorey.com<mailto:lists@nickshorey.com>; Gregory DiBiase; gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org>; theo geurts; Michele Neylon - Blacknight Cc: Janelle McAlister; Sara Bockey; Dennis Chang; Caitlin Tubergen; Michelle DeSmyter; Marano, Phillip V.; Francisco Arias; Victoria Sheckler; Jennifer Gore; Metalitz, Steven; Barnett, Griffin M.; Maguy Serad; Jennifer Scott; Owen Smigelski; Glen de Saint Géry; David Hughes Subject: FW: PP IRT/PSWG discussion When: Thursday, June 29, 2017 3:00 AM-4:00 AM (UTC-05:00) Eastern Time (US & Canada). Where: ICANN59 - Pavilion S8 Hi guys, Is there any chance any of you can make this one? We have several RSVPs but no "yes's" from registrars (Volker was a maybe). -----Original Appointment----- From: Sent: Wednesday, June 28, 2017 10:48 AM To: Amy Bivins; lists(a)nickshorey.com<mailto:lists@nickshorey.com>; gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Cc: Janelle McAlister; Sara Bockey; Dennis Chang; Caitlin Tubergen; Michelle DeSmyter; Marano, Phillip V.; Francisco Arias; Victoria Sheckler; Jennifer Gore; Metalitz, Steven; Barnett, Griffin M.; Maguy Serad; Jennifer Scott; Owen Smigelski; Glen de Saint Géry; David Hughes Subject: PP IRT/PSWG discussion When: Thursday, June 29, 2017 9:00 AM-10:00 AM Harare, Pretoria. Where: ICANN59 - Pavilion S8 Dear Colleagues, We found space available for a continuation of the IRT/PSWG discussion from Monday, if you are able to attend. Remote participation will not be available in this room, but detailed notes will be shared with the full IRT and PSWG following this meeting, and posted on the public wiki. IRT members, please let me know if you are in J'burg and able to attend, as we should cancel if we can't get several people in the room. Best, Amy

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PP IRT/PSWG discussion
by Amy Bivins June 28, 2017

June 28, 2017

Dear Colleagues, We found space available for a continuation of the IRT/PSWG discussion from Monday, if you are able to attend. Remote participation will not be available in this room, but detailed notes will be shared with the full IRT and PSWG following this meeting, and posted on the public wiki. IRT members, please let me know if you are in J'burg and able to attend, as we should cancel if we can't get several people in the room. Best, Amy

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Notes, Action Items from PP IRT/PSWG meeting today at ICANN59
by Amy Bivins June 27, 2017

June 27, 2017

Nick, Thanks so much for you and your colleagues' participation in the privacy/proxy IRT meeting today. I think we made a lot of progress. I'm attaching a brief summary of the notes I was able to take on remote (the audio was not available for the first several minutes but I believe I caught all of the substantive discussion). We kindly ask the PSWG to provide any additional input you can on the redline draft and the points raised during the meeting this morning after you wrap up your discussions this week. I understand you would like to meet again with any IRT members who are available to discuss the last discussion point. Can you provide some suggested times for tomorrow and Thursday (tomorrow is likely better as I expect folks may start to travel Thurs) and I'll try to find some space and a time when at least some IRT members are available? Also, please discuss with your colleagues how you'd like to proceed to collaborate with the IRT on this document. We could schedule calls or pass drafts back and forth (drafts may be more efficient at this point given the upcoming summer holiday season). Ideally we will be able to finish this up in July, if at all possible, at least for purposes of having a draft ready to go into the draft PPAA for public comment. 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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REMINDER: Privacy/Proxy IRT meeting with GAC PSWG at ICANN59
by Amy Bivins June 26, 2017

June 26, 2017

Dear Colleagues, This is a reminder that the Privacy/Proxy Service Provider Accreditation Program IRT will meet with the GAC Public Safety Working Group tomorrow, from 1215-1300 UTC (1415-1500 local time) in Boardroom 3. Remote login information is available below. Space in the room is limited, so please plan to arrive early if you plan to participate in the discussion. The agenda for the session is as follows: * Introduction (led by Jennifer Gore) * IRT overview of proposed discussion topics (led by IRT members Roger Carney, Greg DiBiase and Eric Rokobauer) * PSWG/IRT Discussion of IRT feedback * Section 1.4 * Section 1.5 * Section 3.1 * Section 3.2.1 * AOB * Next steps (led by Jennifer Gore) A redline discussion draft of the PSWG's initial LEA discussion framework draft is attached. Jennifer Gore will be facilitating this session on staff's behalf, as I will be remote, but I will be in the Adobe room and on audio to answer any questions or provide additional background or information that may be needed. If you have questions, please don't hesitate to contact me. 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> -----Original Appointment----- From: Amy Bivins Sent: Monday, June 19, 2017 8:57 AM To: Amy Bivins; gdd-gnso-ppsai-impl(a)icann.org; Michelle DeSmyter; Fabien Betremieux; Nick Shorey Cc: Trang Nguyen; Phil Corwin; Glen de Saint Géry; Janelle McAlister; Shawn White; Caitlin Tubergen; Roger D Carney; Barnett, Griffin M.; David Hughes; Marano, Phillip V.; Dennis Chang; Owen Smigelski; David Haenel; Francisco Arias; DiBiase, Gregory; Sara Bockey; Metalitz, Steven; Deacon, Alex; Victoria Sheckler; Mary Wong; Terri Agnew; Chris Pelling; Jennifer Scott; Maguy Serad; Russ Weinstein; Jennifer Gore; Volker Greimann; Michele Neylon - Blacknight; Walden, Thomas L.; KIMPIAN Peter; Sansbury, Amy J.; Gulten Tepe; Julia Charvolen; Miguel Angel Munoz Petrichole; Jason Plomp; Eric Rokobauer; Landry-Morson, Lise (IC); Marcolla, Sara Veronica Subject: Privacy/Proxy IRT meeting with GAC PSWG When: Tuesday, June 27, 2017 8:15 AM-9:00 AM (UTC-05:00) Eastern Time (US & Canada). Where: ICANN59--Board Room 3 (and remote) Dear Colleagues, The Privacy and Proxy Service Provider Accreditation IRT will meet with the GAC PSWG during ICANN 59, on Tuesday, 27 June, from 14:15-15:00 local time. For those of you who are able to attend in person, the room is currently scheduled to be held in Board Room 3 (if this changes, I will update the invite accordingly). For those who cannot attend in person, login details are below. As this is currently scheduled to be in a conference room rather than one of the main meeting rooms, the meeting will be run as a regular IRT meeting, at the usual location. Adobe Connect link: https://participate.icann.org/ppirt Participant code: 4824695647 Dial-In Phone Numbers: US: +1-719-457-6209 Canada, Calgary: +1 403 407 5793 Canada, Montreal: +1 514 669 5928 Canada, Toronto: +1 647 426 9172 Canada, Vancouver: +1 604 222 7836 Argentina (toll free): 0800 800 1223 Argentina, Buenos Aires: +54 (0) 11 5172 6003 Australia (toll free): 1 800 804 786 Australia, Brisbane: +61 (0) 7 3015 0535 Australia, Melbourne: +61 (0) 3 8687 0553 Australia, Sydney: +61 (0) 2 8017 6064 Austria (toll free): 0800 8866 3413 Austria, Vienna: +43 (0) 1 25302 1785 Bahrain (toll free): 800 04212 Bahrain, Manama: +973 1619 8739 Belarus (toll free): 8 820 0011 0341 Belgium (toll free): 0800 39279 Belgium, Brussels: +32 (0) 2 400 6928 Brazil (toll free): 0800 887 0233 Brazil, Rio de Janeiro: +55 21 4560 0072 Brazil, Sao Paulo: +55 11 4935 7169 Bulgaria (toll free): 00800 111 4950 Bulgaria, Sofia: +359 (0) 2 491 6045 Canada (toll free): 1 855 950 3717 Chile (toll free): 171 800 835 783 Chile, Santiago: +56 (0) 2 2666 0696 China (national): +400 613 8103 China, Beijing: +86 10 5667 0003 China, Shanghai: +86 21 2039 7081 Colombia (toll free): 01 800 755 0102 Colombia, Bogota: +57 1 508 8137 Croatia (toll free): 0800 805 940 Cyprus (toll free): 800 97424 Czech Republic (toll free): 800 701 532 Czech Republic, Prague: +420 225 986 554 Denmark (toll free): 80 70 35 86 Denmark, Copenhagen: +45 32 72 78 10 Egypt (toll free): 0800 000 0593 Estonia (toll free): 800 011 1589 Estonia, Tallinn: +372 622 6551 Fiji (toll free): 00800 3322 Finland (toll free): 0800 772 236 Finland, Helsinki: +358 (0) 9 2310 1677 France (national): 0811 655 100 France (toll free): 0800 946 531 France, Paris: +33 (0) 1 70 37 16 56 Germany (national): 01801 003 899 Germany (toll free): 0800 588 9170 Germany, Frankfurt: +49 (0) 69 2222 10612 Germany, Munich: +49 (0) 89 2030 31207 Greece (toll free): 00800 128 913 Greece, Athens: +30 211 181 3824 Hong Kong: +852 3018 9111 Hong Kong (toll free): 800 901 787 Hungary (toll free): 068 001 9673 Hungary, Budapest: +36 1408 8953 Iceland (toll free): 800 9847 India, Bangalore: +91 (0) 80 6127 6710 India, Chennai: +91 (0)44 6688 6061 India, Delhi: +91 (0) 11 6641 1394 India, Mumbai: +91 (0)22 6187 5028 Indonesia (toll free): 007 803 321 8927 Ireland (national): 1890 907 630 Ireland (toll free): 1800 937 649 Ireland, Dublin: +353 (0) 1 526 9421 Israel (toll free): 1809 213 168 Israel, Tel Aviv: +972 (0)3 721 7943 Italy (toll free): 800 146 094 Italy, Milan: +39 02 3600 8006 Italy, Rome: +39 06 8750 0676 Japan (mobile): 0120 632 611 Japan (toll free): 0120 305 211 Japan, Osaka: +81 (0) 6 4560 2410 Japan, Tokyo: +81 (0) 3 4560 1270 Kazakhstan (toll free): 8800 333 7554 Latvia (toll free): 8000 4418 Latvia, Riga: +371 6601 3627 Lithuania (toll free): 8800 31449 Lithuania, Vilnius: +370 5205 5468 Luxembourg: +352 2088 1749 Luxembourg (toll free): 800 28433 Malaysia (toll free): 1 800 816 152 Malaysia,Kuala Lumpur: +60 (0) 3 7724 8010 Mexico (toll free): 01 800 733 4102 Mexico, Guadalajara: +52 33 4162 4504 Mexico, Mexico City: +52 55 8421 0326 Mexico, Monterrey: +52 81 4162 5648 Morocco (toll free): 0800 091 296 Morocco, Casablanca: +212 (0) 520 48 0022 Netherlands (toll free): 0800 020 2597 Netherlands, Amsterdam: +31 (0) 20 716 8345 New Zealand (toll free): 0800 452 947 New Zealand, Auckland: +64 (0) 9 929 1825 New Zealand, Christchurch: +64 (0) 3 974 2596 New Zealand, Wellington: +64 (0) 4 909 4674 Nigeria, Lagos: +234 1 277 3944 Norway (toll free): 800 56081 Norway, Oslo: +47 21 00 48 15 Panama (toll free): 00800 223 1390 Panama, Panama City: +507 8 335 913 Peru, Lima: +51 (0) 1 700 9571 Philippines (toll free): 1 800 111 013 99 Philippines, Manila: +63 (0)2 395 3426 Poland (toll free): 00 800 121 4356 Poland, Warsaw: +48 22 295 3570 Portugal (toll free): 800 784 442 Portugal, Lisbon: +351 21 316 4093 Qatar (toll free): 00 800 100 491 Romania (toll free): 0800 801 035 Romania, Bucharest: +40 (0) 21 529 3992 Russia (toll free): 8 800 500 9241 Russia, Moscow: +7 495 646 9181 Saudi Arabia (toll free): 800 844 6641 Saudi Arabia (toll free): 800 850 0219 Singapore: +65 6622 1957 Singapore (toll free): 800 616 3192 Slovakia (toll free): 0800 002 002 Slovakia, Bratislava: +421 (0)2 3321 5498 Slovenia (toll free): 0800 81193 Slovenia, Ljubljana: +386 1600 8695 South Africa (toll free): 0800 999 434 South Africa, Johannesburg: +27 (0)11 589 8321 South Korea (toll free): 00798 6136 1454 South Korea, Seoul: +82 (0) 2 6007 0079 Spain (toll free): 900 828 035 Spain, Barcelona: +34 93 800 1946 Spain, Madrid: +34 91 114 6653 Sweden (toll free): 0200 125 588 Sweden, Stockholm: +46 (0) 8 5065 3956 Switzerland (toll free): 0800 740 360 Switzerland, Geneva: +41 (0) 22 595 4795 Switzerland, Zurich: +41 (0) 44 580 7207 Taiwan (toll free): 0800 666 596 Taiwan, Taipei: +886 (0) 2 2650 7329 Thailand (toll free): 001 800 6136 1473 Turkey (toll free): 00800 4488 26642 Turkey, Istanbul: +90 212 375 50 49 UAE (toll free): 8000 3570 2662 UK (03): +44 (0)330 336 6002 UK (toll free): 0800 358 6385 Ukraine (toll free): 0800 500 896 Uruguay (toll free): 0004 019 0152 USA /Canada (toll free): 1-866-398-2885 Venezuela (toll free): 0 800 162 7451 Vietnam (toll free): 1800 9226 Costa Rica (toll free): 800 542 5328 France (national): 0821 231 671 India (toll free): 1800 200 9415 Indonesia, Jakarta: +62 21 2188 9084 Ireland (national): 0818 270 271 Japan (national): 0570 085 744 Serbia (toll free): 0800 190 712 UK (national): 0844 473 5010 UK (national): 0845 545 0015 Venezuela, Caracas: +58 212 720 2164

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Discussion document, proposed agenda for PP IRT/PSWG meeting at ICANN59
by Amy Bivins June 22, 2017

June 22, 2017

Nick and Fabien, Attached, you will find a markup of the PSWG's LEA disclosure framework proposal, including items that the IRT wishes to discuss during the face-to-face in J'burg. The most substantive topics are in Sections 1.4, 1.5, 3.1 and 3.2.1. Given the very short 45-minute meeting time, I'd suggest that discussion start on those points so that time isn't lost during the F2F on some of the more minor suggested edits. As you know, I am not traveling to ICANN59, but I will be dialed in. Jennifer Gore is going to be the staff facilitator, as logistics may make it difficult to facilitate remotely. Proposed Agenda * Intro (Jennifer Gore) * IRT overview of proposed discussion topics (IRT members Roger Carney and Eric Rokobauer have offered to lead) * IRT/PSWG discussion * Next steps-Plan for IRT/PSWG refinement of draft framework as materials are prepared for public comment Meeting Details * Tuesday, 27 June, 1415-1500 local time * Location: Boardroom 3 (Note-this is a very small room that seats approximately 24 people. Seating preference will be given to IRT and PSWG members and staff facilitator) * Remote participation link: https://participate.icann.org/ppirt * Phone bridge information will be distributed in separate meeting invite. We look forward to what we hope will be a productive discussion and thank you and your team for your help in securing meeting space and logistics on-site. If you have questions or suggestions in the interim, please don't hesitate to contact me. Best, 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/Proxy IRT meeting with GAC PSWG
by Amy Bivins June 22, 2017

June 22, 2017

Dear Colleagues, The Privacy and Proxy Service Provider Accreditation IRT will meet with the GAC PSWG during ICANN 59, on Tuesday, 27 June, from 14:15-15:00 local time. For those of you who are able to attend in person, the room is currently scheduled to be held in Board Room 3 (if this changes, I will update the invite accordingly). For those who cannot attend in person, login details are below. As this is currently scheduled to be in a conference room rather than one of the main meeting rooms, the meeting will be run as a regular IRT meeting, at the usual location. Adobe Connect link: https://participate.icann.org/ppirt Participant code: 4824695647 Dial-In Phone Numbers: US: +1-719-457-6209 Canada, Calgary: +1 403 407 5793 Canada, Montreal: +1 514 669 5928 Canada, Toronto: +1 647 426 9172 Canada, Vancouver: +1 604 222 7836 Argentina (toll free): 0800 800 1223 Argentina, Buenos Aires: +54 (0) 11 5172 6003 Australia (toll free): 1 800 804 786 Australia, Brisbane: +61 (0) 7 3015 0535 Australia, Melbourne: +61 (0) 3 8687 0553 Australia, Sydney: +61 (0) 2 8017 6064 Austria (toll free): 0800 8866 3413 Austria, Vienna: +43 (0) 1 25302 1785 Bahrain (toll free): 800 04212 Bahrain, Manama: +973 1619 8739 Belarus (toll free): 8 820 0011 0341 Belgium (toll free): 0800 39279 Belgium, Brussels: +32 (0) 2 400 6928 Brazil (toll free): 0800 887 0233 Brazil, Rio de Janeiro: +55 21 4560 0072 Brazil, Sao Paulo: +55 11 4935 7169 Bulgaria (toll free): 00800 111 4950 Bulgaria, Sofia: +359 (0) 2 491 6045 Canada (toll free): 1 855 950 3717 Chile (toll free): 171 800 835 783 Chile, Santiago: +56 (0) 2 2666 0696 China (national): +400 613 8103 China, Beijing: +86 10 5667 0003 China, Shanghai: +86 21 2039 7081 Colombia (toll free): 01 800 755 0102 Colombia, Bogota: +57 1 508 8137 Croatia (toll free): 0800 805 940 Cyprus (toll free): 800 97424 Czech Republic (toll free): 800 701 532 Czech Republic, Prague: +420 225 986 554 Denmark (toll free): 80 70 35 86 Denmark, Copenhagen: +45 32 72 78 10 Egypt (toll free): 0800 000 0593 Estonia (toll free): 800 011 1589 Estonia, Tallinn: +372 622 6551 Fiji (toll free): 00800 3322 Finland (toll free): 0800 772 236 Finland, Helsinki: +358 (0) 9 2310 1677 France (national): 0811 655 100 France (toll free): 0800 946 531 France, Paris: +33 (0) 1 70 37 16 56 Germany (national): 01801 003 899 Germany (toll free): 0800 588 9170 Germany, Frankfurt: +49 (0) 69 2222 10612 Germany, Munich: +49 (0) 89 2030 31207 Greece (toll free): 00800 128 913 Greece, Athens: +30 211 181 3824 Hong Kong: +852 3018 9111 Hong Kong (toll free): 800 901 787 Hungary (toll free): 068 001 9673 Hungary, Budapest: +36 1408 8953 Iceland (toll free): 800 9847 India, Bangalore: +91 (0) 80 6127 6710 India, Chennai: +91 (0)44 6688 6061 India, Delhi: +91 (0) 11 6641 1394 India, Mumbai: +91 (0)22 6187 5028 Indonesia (toll free): 007 803 321 8927 Ireland (national): 1890 907 630 Ireland (toll free): 1800 937 649 Ireland, Dublin: +353 (0) 1 526 9421 Israel (toll free): 1809 213 168 Israel, Tel Aviv: +972 (0)3 721 7943 Italy (toll free): 800 146 094 Italy, Milan: +39 02 3600 8006 Italy, Rome: +39 06 8750 0676 Japan (mobile): 0120 632 611 Japan (toll free): 0120 305 211 Japan, Osaka: +81 (0) 6 4560 2410 Japan, Tokyo: +81 (0) 3 4560 1270 Kazakhstan (toll free): 8800 333 7554 Latvia (toll free): 8000 4418 Latvia, Riga: +371 6601 3627 Lithuania (toll free): 8800 31449 Lithuania, Vilnius: +370 5205 5468 Luxembourg: +352 2088 1749 Luxembourg (toll free): 800 28433 Malaysia (toll free): 1 800 816 152 Malaysia,Kuala Lumpur: +60 (0) 3 7724 8010 Mexico (toll free): 01 800 733 4102 Mexico, Guadalajara: +52 33 4162 4504 Mexico, Mexico City: +52 55 8421 0326 Mexico, Monterrey: +52 81 4162 5648 Morocco (toll free): 0800 091 296 Morocco, Casablanca: +212 (0) 520 48 0022 Netherlands (toll free): 0800 020 2597 Netherlands, Amsterdam: +31 (0) 20 716 8345 New Zealand (toll free): 0800 452 947 New Zealand, Auckland: +64 (0) 9 929 1825 New Zealand, Christchurch: +64 (0) 3 974 2596 New Zealand, Wellington: +64 (0) 4 909 4674 Nigeria, Lagos: +234 1 277 3944 Norway (toll free): 800 56081 Norway, Oslo: +47 21 00 48 15 Panama (toll free): 00800 223 1390 Panama, Panama City: +507 8 335 913 Peru, Lima: +51 (0) 1 700 9571 Philippines (toll free): 1 800 111 013 99 Philippines, Manila: +63 (0)2 395 3426 Poland (toll free): 00 800 121 4356 Poland, Warsaw: +48 22 295 3570 Portugal (toll free): 800 784 442 Portugal, Lisbon: +351 21 316 4093 Qatar (toll free): 00 800 100 491 Romania (toll free): 0800 801 035 Romania, Bucharest: +40 (0) 21 529 3992 Russia (toll free): 8 800 500 9241 Russia, Moscow: +7 495 646 9181 Saudi Arabia (toll free): 800 844 6641 Saudi Arabia (toll free): 800 850 0219 Singapore: +65 6622 1957 Singapore (toll free): 800 616 3192 Slovakia (toll free): 0800 002 002 Slovakia, Bratislava: +421 (0)2 3321 5498 Slovenia (toll free): 0800 81193 Slovenia, Ljubljana: +386 1600 8695 South Africa (toll free): 0800 999 434 South Africa, Johannesburg: +27 (0)11 589 8321 South Korea (toll free): 00798 6136 1454 South Korea, Seoul: +82 (0) 2 6007 0079 Spain (toll free): 900 828 035 Spain, Barcelona: +34 93 800 1946 Spain, Madrid: +34 91 114 6653 Sweden (toll free): 0200 125 588 Sweden, Stockholm: +46 (0) 8 5065 3956 Switzerland (toll free): 0800 740 360 Switzerland, Geneva: +41 (0) 22 595 4795 Switzerland, Zurich: +41 (0) 44 580 7207 Taiwan (toll free): 0800 666 596 Taiwan, Taipei: +886 (0) 2 2650 7329 Thailand (toll free): 001 800 6136 1473 Turkey (toll free): 00800 4488 26642 Turkey, Istanbul: +90 212 375 50 49 UAE (toll free): 8000 3570 2662 UK (03): +44 (0)330 336 6002 UK (toll free): 0800 358 6385 Ukraine (toll free): 0800 500 896 Uruguay (toll free): 0004 019 0152 USA /Canada (toll free): 1-866-398-2885 Venezuela (toll free): 0 800 162 7451 Vietnam (toll free): 1800 9226 Costa Rica (toll free): 800 542 5328 France (national): 0821 231 671 India (toll free): 1800 200 9415 Indonesia, Jakarta: +62 21 2188 9084 Ireland (national): 0818 270 271 Japan (national): 0570 085 744 Serbia (toll free): 0800 190 712 UK (national): 0844 473 5010 UK (national): 0845 545 0015 Venezuela, Caracas: +58 212 720 2164

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[Action Required by EOD Wednesday] last call for input on PSWG proposal, labeling/escrow poll
by Amy Bivins June 21, 2017

June 21, 2017

Dear Colleagues, Thank you for your active participation on the Privacy/Proxy IRT call today. As mentioned on the call, please provide any final feedback on the PSWG discussion document (for distribution to the PSWG on Thursday for discussion at ICANN59) no later than your EOD tomorrow, Wednesday, 21 June. The draft document is attached. Per our discussion on RDDS labeling, please complete the linked poll no later than your EOD Thursday, https://www.surveymonkey.com/r/WZRFV3P. Your answers on the labeling questions will be used to finalize the draft specification for the first discussion draft of the PPAA, which the IRT is expected to begin reviewing in July. The poll also includes two questions related to data escrow. These questions are intended to solicit initial IRT opinions only, as this topic will be discussed again in more detail on a future IRT call (likely in early July). Safe travels to all of you who are traveling to ICANN59, and I hope you all have a great rest of your 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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Please Review: PP IRT draft v1 redline of PSWG proposal attached
by Amy Bivins June 20, 2017

June 20, 2017

Dear Colleagues, Thanks so much for your active participation on yesterday's call. Pursuant to the IRT's discussion yesterday on the PSWG proposal, I'm attaching a first draft of a markup of the PSWG proposal for your review. Please review and provide any additional suggested edits or comments that you would like to discuss on next week's call no later than your EOD Monday (but earlier is better!). I'm also attaching a summary of all of your comments from yesterday's discussion, as well as a document detailing all of your prior input on this proposal. The goal is to finalize this discussion draft shortly after next week's call (20 June) so that it can be distributed to the PSWG in preparation for the IRT/PSWG meeting at ICANN59. For those who could not attend, I encourage you to listen to the call recording (available on the wiki, https://participate.icann.org/p1zlpvjfw5i/) Unfortunately, there is a problem with the last 10-12 minutes of the recording, with the host and participant audio not recording in sync, but you can still hear most of what was said during the meeting. 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/Proxy IRT meeting with GAC PSWG
by Amy Bivins June 19, 2017

June 19, 2017

Dear Colleagues, The Privacy and Proxy Service Provider Accreditation IRT will meet with the GAC PSWG during ICANN 59, on Tuesday, 27 June, from 14:15-15:00 local time. For those of you who are able to attend in person, the room is currently scheduled to be held in Committee Room 1 (if this changes, I will update the invite accordingly). For those who cannot attend in person, login details are below. As this is currently scheduled to be in a conference room rather than one of the main meeting rooms, the meeting will be run as a regular IRT meeting, at the usual location. Adobe Connect link: https://participate.icann.org/ppirt Participant code: 4824695647 Dial-In Phone Numbers: US: +1-719-457-6209 Canada, Calgary: +1 403 407 5793 Canada, Montreal: +1 514 669 5928 Canada, Toronto: +1 647 426 9172 Canada, Vancouver: +1 604 222 7836 Argentina (toll free): 0800 800 1223 Argentina, Buenos Aires: +54 (0) 11 5172 6003 Australia (toll free): 1 800 804 786 Australia, Brisbane: +61 (0) 7 3015 0535 Australia, Melbourne: +61 (0) 3 8687 0553 Australia, Sydney: +61 (0) 2 8017 6064 Austria (toll free): 0800 8866 3413 Austria, Vienna: +43 (0) 1 25302 1785 Bahrain (toll free): 800 04212 Bahrain, Manama: +973 1619 8739 Belarus (toll free): 8 820 0011 0341 Belgium (toll free): 0800 39279 Belgium, Brussels: +32 (0) 2 400 6928 Brazil (toll free): 0800 887 0233 Brazil, Rio de Janeiro: +55 21 4560 0072 Brazil, Sao Paulo: +55 11 4935 7169 Bulgaria (toll free): 00800 111 4950 Bulgaria, Sofia: +359 (0) 2 491 6045 Canada (toll free): 1 855 950 3717 Chile (toll free): 171 800 835 783 Chile, Santiago: +56 (0) 2 2666 0696 China (national): +400 613 8103 China, Beijing: +86 10 5667 0003 China, Shanghai: +86 21 2039 7081 Colombia (toll free): 01 800 755 0102 Colombia, Bogota: +57 1 508 8137 Croatia (toll free): 0800 805 940 Cyprus (toll free): 800 97424 Czech Republic (toll free): 800 701 532 Czech Republic, Prague: +420 225 986 554 Denmark (toll free): 80 70 35 86 Denmark, Copenhagen: +45 32 72 78 10 Egypt (toll free): 0800 000 0593 Estonia (toll free): 800 011 1589 Estonia, Tallinn: +372 622 6551 Fiji (toll free): 00800 3322 Finland (toll free): 0800 772 236 Finland, Helsinki: +358 (0) 9 2310 1677 France (national): 0811 655 100 France (toll free): 0800 946 531 France, Paris: +33 (0) 1 70 37 16 56 Germany (national): 01801 003 899 Germany (toll free): 0800 588 9170 Germany, Frankfurt: +49 (0) 69 2222 10612 Germany, Munich: +49 (0) 89 2030 31207 Greece (toll free): 00800 128 913 Greece, Athens: +30 211 181 3824 Hong Kong: +852 3018 9111 Hong Kong (toll free): 800 901 787 Hungary (toll free): 068 001 9673 Hungary, Budapest: +36 1408 8953 Iceland (toll free): 800 9847 India, Bangalore: +91 (0) 80 6127 6710 India, Chennai: +91 (0)44 6688 6061 India, Delhi: +91 (0) 11 6641 1394 India, Mumbai: +91 (0)22 6187 5028 Indonesia (toll free): 007 803 321 8927 Ireland (national): 1890 907 630 Ireland (toll free): 1800 937 649 Ireland, Dublin: +353 (0) 1 526 9421 Israel (toll free): 1809 213 168 Israel, Tel Aviv: +972 (0)3 721 7943 Italy (toll free): 800 146 094 Italy, Milan: +39 02 3600 8006 Italy, Rome: +39 06 8750 0676 Japan (mobile): 0120 632 611 Japan (toll free): 0120 305 211 Japan, Osaka: +81 (0) 6 4560 2410 Japan, Tokyo: +81 (0) 3 4560 1270 Kazakhstan (toll free): 8800 333 7554 Latvia (toll free): 8000 4418 Latvia, Riga: +371 6601 3627 Lithuania (toll free): 8800 31449 Lithuania, Vilnius: +370 5205 5468 Luxembourg: +352 2088 1749 Luxembourg (toll free): 800 28433 Malaysia (toll free): 1 800 816 152 Malaysia,Kuala Lumpur: +60 (0) 3 7724 8010 Mexico (toll free): 01 800 733 4102 Mexico, Guadalajara: +52 33 4162 4504 Mexico, Mexico City: +52 55 8421 0326 Mexico, Monterrey: +52 81 4162 5648 Morocco (toll free): 0800 091 296 Morocco, Casablanca: +212 (0) 520 48 0022 Netherlands (toll free): 0800 020 2597 Netherlands, Amsterdam: +31 (0) 20 716 8345 New Zealand (toll free): 0800 452 947 New Zealand, Auckland: +64 (0) 9 929 1825 New Zealand, Christchurch: +64 (0) 3 974 2596 New Zealand, Wellington: +64 (0) 4 909 4674 Nigeria, Lagos: +234 1 277 3944 Norway (toll free): 800 56081 Norway, Oslo: +47 21 00 48 15 Panama (toll free): 00800 223 1390 Panama, Panama City: +507 8 335 913 Peru, Lima: +51 (0) 1 700 9571 Philippines (toll free): 1 800 111 013 99 Philippines, Manila: +63 (0)2 395 3426 Poland (toll free): 00 800 121 4356 Poland, Warsaw: +48 22 295 3570 Portugal (toll free): 800 784 442 Portugal, Lisbon: +351 21 316 4093 Qatar (toll free): 00 800 100 491 Romania (toll free): 0800 801 035 Romania, Bucharest: +40 (0) 21 529 3992 Russia (toll free): 8 800 500 9241 Russia, Moscow: +7 495 646 9181 Saudi Arabia (toll free): 800 844 6641 Saudi Arabia (toll free): 800 850 0219 Singapore: +65 6622 1957 Singapore (toll free): 800 616 3192 Slovakia (toll free): 0800 002 002 Slovakia, Bratislava: +421 (0)2 3321 5498 Slovenia (toll free): 0800 81193 Slovenia, Ljubljana: +386 1600 8695 South Africa (toll free): 0800 999 434 South Africa, Johannesburg: +27 (0)11 589 8321 South Korea (toll free): 00798 6136 1454 South Korea, Seoul: +82 (0) 2 6007 0079 Spain (toll free): 900 828 035 Spain, Barcelona: +34 93 800 1946 Spain, Madrid: +34 91 114 6653 Sweden (toll free): 0200 125 588 Sweden, Stockholm: +46 (0) 8 5065 3956 Switzerland (toll free): 0800 740 360 Switzerland, Geneva: +41 (0) 22 595 4795 Switzerland, Zurich: +41 (0) 44 580 7207 Taiwan (toll free): 0800 666 596 Taiwan, Taipei: +886 (0) 2 2650 7329 Thailand (toll free): 001 800 6136 1473 Turkey (toll free): 00800 4488 26642 Turkey, Istanbul: +90 212 375 50 49 UAE (toll free): 8000 3570 2662 UK (03): +44 (0)330 336 6002 UK (toll free): 0800 358 6385 Ukraine (toll free): 0800 500 896 Uruguay (toll free): 0004 019 0152 USA /Canada (toll free): 1-866-398-2885 Venezuela (toll free): 0 800 162 7451 Vietnam (toll free): 1800 9226 Costa Rica (toll free): 800 542 5328 France (national): 0821 231 671 India (toll free): 1800 200 9415 Indonesia, Jakarta: +62 21 2188 9084 Ireland (national): 0818 270 271 Japan (national): 0570 085 744 Serbia (toll free): 0800 190 712 UK (national): 0844 473 5010 UK (national): 0845 545 0015 Venezuela, Caracas: +58 212 720 2164

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Agenda, discussion questions for PP IRT meeting 20 June
by Amy Bivins June 18, 2017

June 18, 2017

Dead Colleagues, The next Privacy and Proxy Service Provider Accreditation Program IRT meeting is scheduled for Tuesday, 20 June, at 1400 UTC. I hope you can all attend. In advance of the call, please review and share any feedback you have on the draft PSWG proposal redline/discussion document on the list (and come to the call prepared to discuss so that we can finalize this document by Weds.). In addition, we plan to discuss the following topics: (1) Logistics for ICANN59 session with PSWG (2) RDDS labeling-seeking final IRT input on labeling requirement (poll will also be distributed on Tuesday). The options are: a. Require Provider name, ICANN ID, and URL for ICANN-managed webpage in Registrant Name or Registrant Organization field. b. Require Provider name and ICANN ID in Registrant Name or Registrant Organization field. c. Require Provider name, ICANN ID, and URL for ICANN-managed webpage in Registrant Organization field. d. Require Provider name and ICANN ID in Registrant Organization field. (3) Data Escrow-seeking IRT input on specific escrow requirements. Industry standards for data escrow have been updated since the RAA was drafted. Ideally, these newly accredited providers would be subject to the most up-to-date standards, but this could create issues if a Provider is able to satisfy data escrow requirements via an Affiliated registrar's deposits. This issue will be discussed on the call and a follow-up poll will be distributed so that we can determine which specifications should be added to the draft v1 PPAA. (4) Timeline check (if time available). Have a great weekend, all! 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 and agenda for 13 June PP IRT meeting
by Darcy Southwell June 13, 2017

June 13, 2017

Hi, Amy. I expect to be able to attend on June 27. Thanks. Darcy ---------------- Darcy Southwell | Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart 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> Date: Friday, June 9, 2017 at 9:09 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Materials and agenda for 13 June PP IRT meeting Dear Colleagues, On our next PP IRT call, scheduled for 13 June, 1400 UTC, we will continue discussing your feedback on the PSWG proposal. To aid this discussion, I’m attaching two documents that include the input provided from the IRT so far. (1) A detailed account of all IRT feedback submitted, in table format; and (2) A high-level summary of IRT feedback as a markup on the proposal document. On Tuesday, I’m planning to start at the top of the document and we will go through your feedback section by section, and discuss proposed talking points and questions for the PSWG (and proposed edits, if you have any at this stage). The goal of this exercise is to compile a list of significant issues (and proposed changes/solutions) the IRT would like to present to the PSWG for discussion in Johannesburg. We hope to be able to complete this exercise and have a document ready to share with the PSWG before 23 June. As an update on ICANN59 planning, we are still working to secure space for an IRT-PSWG meeting. Due to the late date, availability is a challenge, but we will find a space. We have a tentative spot for Tuesday, 27 June, 14:15-15:00 local time (UTC+2). The room we have available for this time slot is quite small and lacks meeting technical capabilities (microphones, etc), so we are working to find any other better alternative before sending out a meeting invitation. If this is our best option, we will likely run the call as a regular IRT meeting, with audio connected via Adobe Connect. To aid our planning, if you are planning to attend this meeting in person, could you please let me know? Thanks so much in advance, and I look forward to meeting with you on Tuesday. If you have additional comments on the PSWG proposal between now and Tuesday, please share them on 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 www.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 and agenda for 13 June PP IRT meeting
by Amy Bivins June 13, 2017

June 13, 2017

Dear Colleagues, On our next PP IRT call, scheduled for 13 June, 1400 UTC, we will continue discussing your feedback on the PSWG proposal. To aid this discussion, I'm attaching two documents that include the input provided from the IRT so far. (1) A detailed account of all IRT feedback submitted, in table format; and (2) A high-level summary of IRT feedback as a markup on the proposal document. On Tuesday, I'm planning to start at the top of the document and we will go through your feedback section by section, and discuss proposed talking points and questions for the PSWG (and proposed edits, if you have any at this stage). The goal of this exercise is to compile a list of significant issues (and proposed changes/solutions) the IRT would like to present to the PSWG for discussion in Johannesburg. We hope to be able to complete this exercise and have a document ready to share with the PSWG before 23 June. As an update on ICANN59 planning, we are still working to secure space for an IRT-PSWG meeting. Due to the late date, availability is a challenge, but we will find a space. We have a tentative spot for Tuesday, 27 June, 14:15-15:00 local time (UTC+2). The room we have available for this time slot is quite small and lacks meeting technical capabilities (microphones, etc), so we are working to find any other better alternative before sending out a meeting invitation. If this is our best option, we will likely run the call as a regular IRT meeting, with audio connected via Adobe Connect. To aid our planning, if you are planning to attend this meeting in person, could you please let me know? Thanks so much in advance, and I look forward to meeting with you on Tuesday. If you have additional comments on the PSWG proposal between now and Tuesday, please share them on 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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Re: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT call
by Sara Bockey June 7, 2017

June 7, 2017

Hi Amy, Please add me to the TPP sub-team. Thanks, Sara 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, June 6, 2017 at 8:40 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 call Dear Colleagues, Thanks so much for your active participation on the IRT call this week. Per our discussion, please let me know no later than your EOD tomorrow, 7 June, if you would like to be added to the new subteam that will discuss “third party provider” issues. The quick turnaround is so that I can send around a Doodle poll Thurs to hopefully get the subteam meetings started next week. Also, please send any additional feedback you have this week on the PSWG proposal to the list no later than your EOD Friday. We will continue to discuss this topic on next week’s IRT call. Before the call I will distribute a summary of the comments/questions raised to date. We are working to schedule an IRT/PSWG session at ICANN59 and will provide more information as soon as possible. Our goal is to have a list of issues/questions/suggestions related to the PSWG proposal ready to discuss during the meeting in J’burg. The earlier we can get this to the PSWG, the better. Remote participation will be available for that meeting (I will also be remote). 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] Notes, action items from today's PP IRT call
by Chris Pelling June 6, 2017

June 6, 2017

Hi Amy, Please add me to the top subteam as well. >From Chris on the move! On Tue, Jun 6, 2017 at 5:32 PM +0100, "Roger D Carney" <rcarney(a)godaddy.com> wrote: Hi Amy, Please add me to the TPP issues sub-team. Here are some notes on PSWG framework draft. I know a few of these have been mentioned by others (maybe more than once): 2.1.4 Priority Level – 4.1.2 mentions providing justification of priority, should that be a requirement here? 2.1.4 Deadline – probably should be “requested” deadline 4.1.2 How is “actioned” defined 4.2.2.3 How is safety defined? Thanks Roger From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, June 06, 2017 10:40 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Notes, action items from today's PP IRT call Dear Colleagues, Thanks so much for your active participation on the IRT call this week. Per our discussion, please let me know no later than your EOD tomorrow, 7 June, if you would like to be added to the new subteam that will discuss “third party provider” issues. The quick turnaround is so that I can send around a Doodle poll Thurs to hopefully get the subteam meetings started next week. Also, please send any additional feedback you have this week on the PSWG proposal to the list no later than your EOD Friday. We will continue to discuss this topic on next week’s IRT call. Before the call I will distribute a summary of the comments/questions raised to date. We are working to schedule an IRT/PSWG session at ICANN59 and will provide more information as soon as possible. Our goal is to have a list of issues/questions/suggestions related to the PSWG proposal ready to discuss during the meeting in J’burg. The earlier we can get this to the PSWG, the better. Remote participation will be available for that meeting (I will also be remote). 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 www.icann.org

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Notes, action items from today's PP IRT call
by Amy Bivins June 6, 2017

June 6, 2017

Dear Colleagues, Thanks so much for your active participation on the IRT call this week. Per our discussion, please let me know no later than your EOD tomorrow, 7 June, if you would like to be added to the new subteam that will discuss "third party provider" issues. The quick turnaround is so that I can send around a Doodle poll Thurs to hopefully get the subteam meetings started next week. Also, please send any additional feedback you have this week on the PSWG proposal to the list no later than your EOD Friday. We will continue to discuss this topic on next week's IRT call. Before the call I will distribute a summary of the comments/questions raised to date. We are working to schedule an IRT/PSWG session at ICANN59 and will provide more information as soon as possible. Our goal is to have a list of issues/questions/suggestions related to the PSWG proposal ready to discuss during the meeting in J'burg. The earlier we can get this to the PSWG, the better. Remote participation will be available for that meeting (I will also be remote). 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] Fwd: PSWG proposal
by Michele Neylon - Blacknight June 6, 2017

June 6, 2017

Amy / Nick I’ll try to make the call today, but I am having issues juggling meetings / calls etc., In relation to the document shared by Nick: 1.5 – is there a list of priority levels? One of my concerns with this is that the lazy method would be to always set the level as “fastest” or “top priority”. I see there are two rather vague ones mentioned elsewhere in the document. 3.2 the 24 hour timeframe is not workable. I assume the timing has been copied from 3.18 in the 2013 RAA. Unfortunately there is a significant difference. The disclosure framework outlined by Nick is very “legalistic” so it would require the provider to get legal advice before being able to respond. I don’t think I’d be able to even reach our main legal counsel on a Saturday night, let alone get a response from him that could be used. And if I did the cost would be untenable. I’d be happy to acknowledge the request within 24 hours, but I don’t think that the current wording is workable. The language around “secure mechanism” does concern me – it needs to be fleshed out a bit 4.2.3 – “This must be completed prior to any Customer Notification irrespective of the reason for refusal” – I don’t see how or why we would agree to this. Unless you have a court order or similar gagging us. Also it’s inconsistent with the grounds for refusal. 4.3.3 – sorry, but again I don’t see why we’d agree to this. 6.3 – this seems to contradict the other references to customer notification 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: Sunday 4 June 2017 at 12:10 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Fwd: PSWG proposal Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists(a)nickshorey.com<mailto:lists@nickshorey.com>> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> Cc: Fabien Betremieux <fabien.betremieux(a)icann.org<mailto:fabien.betremieux@icann.org>> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists(a)nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nic…> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=Dw…> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone

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Materials, IRT Action Items from 30 May PP Call
by Amy Bivins June 5, 2017

June 5, 2017

Dear Colleagues, Thanks so much for your active participation on today's Privacy/Proxy IRT call. If you were unable to attend, I encourage you to listen to the recording because we covered a lot of ground today. The recording is available on the wiki, https://participate.icann.org/p6bxagpwaq9/ IRT Action Items (1) Please submit any additional feedback you have on the draft v1 applicant guide (attached) by Friday. We will be discussing again and there will be more opportunities for discussion, but the more feedback we have now the better, as we will use the feedback received this week in drafting v2. A summary of your feedback received to date on the applicant guide is attached. I am also attaching the results of the IRT survey of initial operational questions that you completed back in February-this came up briefly on today's call. I apologize that I over-stated the point referenced today on the call-I said that the majority of the IRT said in the poll that the existence of a PP Provider application and/or the contents of an application for accreditation should not be made public. This is true-there was a slight majority of the IRT for this point on each of the questions, but it was a very close result for both questions and the number of participants was relatively low for this poll. (2) Please submit your feedback on the RDDS labeling proposals discussed on today's call no later than Friday. For those not on the call, the Registrar Subteam has developed two possible solutions to implementing the recommendation that registrations involving privacy and/or proxy services should be clearly labeled as such in WHOIS. The first solution would be to (a) require that the privacy/proxy service provider name and ICANN ID appear in the registrant name and/or the registrant organization field (the "or" is to accommodate privacy services where the customer's name appears in the Registrant Name field--this was discussed further on the call). The second solution was (b) require that the privacy/proxy service provider's name, ICANN ID and a URL to the ICANN webpage listing of all accredited providers and contact information. The IRT was roughly split on these proposals. Some IRT members saw an added benefit to the URL (which would provide an easily-identifiable source of Provider contact information that may not be visible in WHOIS), while others thought the URL was unnecessary and could complicate automated uses of the label. If no clear consensus is reached on the list on the path forward on this one, we will take this to a poll. (3) Please submit any additional feedback you have regarding the "unaffiliated provider" issue raised by the registrar subteam today on the call. In summary, members of the registrar subteam have suggested that certain operational issues may make the accreditation of providers that are not affiliated with a registrar highly undesirable or impossible. There have been challenges noted by IRT members and staff throughout this IRT related to unaffiliated providers (particularly in the area of de-accreditation). However, as noted on the call, the Final Report does clearly reference unaffiliated providers, which seems to indicate an intent that unaffiliated providers should be permitted to become accredited. As a result, any potential question/action that would limit eligibility for accreditation by providers that are not affiliated with a registrar would likely need to be taken to the GNSO Council for guidance. At this stage, we are hoping to gather as much IRT input as possible on this so that we can determine how best to proceed. Please send your feedback to the list on this topic this week. As any changes on this point would have a substantial impact on the overall implementation of this program, any action on this should be taken as soon as practicable. Thanks so much for your attention to these matters. Please don't hesitate to contact me or write to the list directly if you have additional comments or questions. 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] Fwd: PSWG proposal
by theo geurts June 4, 2017

June 4, 2017

Sure Nick, no worries, I don't mind. Best regards, Theo On 4-6-2017 18:13, Nick Shorey Lists wrote: > Hi Theo, > > Thanks for the email. If you don't mind I'll hold until Tuesday, but > it's a good question to raise, and certainly one I'm keen to discuss > in practical terms with the experts within this group. > > Kind regards, > > Nick > > Nick Shorey > Phone: +44 (0) 7552 455 988 > Email: lists(a)nickshorey.com <mailto:lists@nickshorey.com> > Skype: nick.shorey > Twitter: @nickshorey > LinkedIn: www.linkedin.com/in/nicklinkedin > <http://www.linkedin.com/in/nicklinkedin> > Web: www.nickshorey.com <http://www.nickshorey.com> > > On 4 Jun 2017, at 13:11, theo geurts <gtheo(a)xs4all.nl > <mailto:gtheo@xs4all.nl>> wrote: > > Looking forward to the presentation. > > Nick, can you provide some background on 4.2.1 in advance? If not, no > worries, we will zoom in on it Tuesday, I am just curious and most > likely overthinking what a secure mechanism is, in this scenario. > > /4.2.1 Within the appropriate timeframe consistent with the Priority > Level, the Provider will disclose to Requestor using a secure > mechanism the Requested Information it holds against the account. / > > Best regards, > > Theo Geurts > > > On 4-6-2017 13:10, Amy Bivins wrote: >> Dear Colleagues, >> >> Please see the PSWG proposal attached, which Nick Shorey will present >> to the IRT on Tuesday. >> >> Best, >> Amy >> >> Sent from my iPhone >> >> Begin forwarded message: >> >>> *From:* Nick Shorey <lists(a)nickshorey.com <mailto:lists@nickshorey.com>> >>> *Date:* June 4, 2017 at 6:42:52 AM EDT >>> *To:* Amy Bivins <amy.bivins(a)icann.org <mailto:amy.bivins@icann.org>> >>> *Cc:* Fabien Betremieux <fabien.betremieux(a)icann.org >>> <mailto:fabien.betremieux@icann.org>> >>> *Subject:* *[Ext] Re: Checking in on PSWG proposal* >>> >>> Hi Amy, >>> >>> Please see attached the Disclosure Framework Principles document, >>> which has now been approved by the GAC. >>> >>> Do send me the details for Tuesday's session, and I look forward to >>> running the rest of the IRT through the document. >>> >>> FYI I did a Webinar for the GAC last week which took around 30 mins >>> - though I anticipate there could be more questions from the IRT so >>> it could run longer. >>> >>> Kind regards, >>> >>> Nick >>> >>> *Nick Shorey* >>> Phone: +44 (0) 7552 455 988 >>> Email: lists(a)nickshorey.com <mailto:lists@nickshorey.com> >>> Skype: nick.shorey >>> Twitter: @nickshorey >>> LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com] >>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nic…> >>> Web: www.nickshorey.com[nickshorey.com] >>> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=Dw…> >>> >>> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins(a)icann.org >>> <mailto:amy.bivins@icann.org>> wrote: >>> >>> Hi Nick, >>> >>> Just checking in-how are things looking for the PSWG proposal >>> for PP? >>> >>> Thanks and have a great weekend! >>> Amy >>> >>> Sent from my iPhone >>> >>> >> >> >> _______________________________________________ >> 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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Fwd: PSWG proposal
by Amy Bivins June 4, 2017

June 4, 2017

Dear Colleagues, Please see the PSWG proposal attached, which Nick Shorey will present to the IRT on Tuesday. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists(a)nickshorey.com<mailto:lists@nickshorey.com>> Date: June 4, 2017 at 6:42:52 AM EDT To: Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> Cc: Fabien Betremieux <fabien.betremieux(a)icann.org<mailto:fabien.betremieux@icann.org>> Subject: [Ext] Re: Checking in on PSWG proposal Hi Amy, Please see attached the Disclosure Framework Principles document, which has now been approved by the GAC. Do send me the details for Tuesday's session, and I look forward to running the rest of the IRT through the document. FYI I did a Webinar for the GAC last week which took around 30 mins - though I anticipate there could be more questions from the IRT so it could run longer. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists(a)nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nic…> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=Dw…> On Sat, Jun 3, 2017 at 4:12 PM, Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> wrote: Hi Nick, Just checking in-how are things looking for the PSWG proposal for PP? Thanks and have a great weekend! Amy Sent from my iPhone

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Agenda for Privacy/Proxy IRT call, 30 May
by Amy Bivins May 26, 2017

May 26, 2017

Dear Colleagues, On our next Privacy/Proxy IRT call, scheduled for Tuesday, 30 May, at 1400 UTC, we will discuss the following: * Update regarding the Registrar Subteam's work on RDDS labeling (Francisco Arias, Technical Services, will be joining us for this discussion); * Discussion of IRT feedback on draft applicant guide. If there are any additional topics you wish to raise, please let me know by responding to the list. I summarize the input we have received to date on the draft applicant guide, but because Monday is a holiday and the meeting is early Tuesday in the US, today is the cutoff for sharing material that will be incorporated into the slide deck. Thanks so much for your participation, and I look forward to speaking with you on Tuesday. Have a great weekend! 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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Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
by Amy Bivins May 26, 2017

May 26, 2017

Dear Colleagues, Thanks so much for your active participation on yesterday's Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017 As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide: (1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached). (2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report. As you are reviewing these documents, please consider the following questions: (a) Is this proposed process consistent with the intent of the Policy recommendations? (b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations? (c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? (d) Are there processes/criteria that may require "implementation adjustment" (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? (e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? Next week's meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May. If you have questions or comments between now and then, please don't hesitate to reply to the list or contact me directly. 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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Fwd: [Ext] Update: PPSAI Disclosure Framework
by Amy Bivins May 12, 2017

May 12, 2017

Dear Colleagues, Please see the update below from Nick Shorey regarding the timeline of the GAC's review of the PSWG proposal. Best, Amy Sent from my iPhone Begin forwarded message: From: Nick Shorey <lists(a)nickshorey.com<mailto:lists@nickshorey.com>> Date: May 12, 2017 at 9:56:04 AM EDT To: Amy Bivins <amy.bivins(a)icann.org<mailto:amy.bivins@icann.org>> Subject: [Ext] Update: PPSAI Disclosure Framework Hi Amy, Hope you're well. Please can you share this update with the members of the IRT. FYI I'm still not receiving any IRT emails on this address - and none caught in my spam - can you double check I'm on the mailing list for lists(a)nickshorey.com<mailto:lists@nickshorey.com>? The draft principles developed by the PSWG for the disclosure framework has now been circulated to the GAC for approval. Due to a busy schedule of ITU meetings affecting many GAC representatives, the deadline has been extended to 2nd June. If approval is given, I then hope to issue this to the IRT on 3rd June. Please accept my apologies for the delays. Kind regards, Nick Nick Shorey Phone: +44 (0) 7552 455 988 Email: lists(a)nickshorey.com<mailto:lists@nickshorey.com> Skype: nick.shorey Twitter: @nickshorey LinkedIn: www.linkedin.com/in/nicklinkedin[linkedin.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_nic…> Web: www.nickshorey.com[nickshorey.com]<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.nickshorey.com&d=Dw…>

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Materials, questions for 16 May Privacy/Proxy IRT Call
by Amy Bivins May 12, 2017

May 12, 2017

Dear Colleagues, I hope you are well. In advance of our call on Tuesday, 16 May, at 15:00 UTC, I am attaching a draft applicant guide, which we will be discussing on the call. Please review this document prior to the call. The document outlines a proposed application process and preliminary evaluation criteria based on the initial discussions we had in April. The document includes a draft application for accreditation that is modeled on the registrar accreditation application, for discussion purposes. As you are reviewing this document, please consider the following questions: (1) Is this proposed process consistent with the intent of the Policy recommendations? (2) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations? (3) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? (4) Are there processes/criteria that may require "implementation adjustment" (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? (5) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? We look forward to speaking with you next week. On the call, I'll provide an overview of the document and then open the call up for IRT discussion on the questions above and any other feedback you have on the document. I encourage you to share any initial thoughts you may have on these questions on the list prior to the call, if you are able, to give other IRT members time to consider issues raised prior to the call. 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 www.icann.org

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Results of IRT poll on PP de-accreditation, next steps
by Amy Bivins May 4, 2017

May 4, 2017

Dear Colleagues, Thank you for your participation in last week's Privacy/Proxy IRT call and the recent poll regarding Privacy/Proxy Provider de-accreditation. A summary of the input received on the call and in the poll is attached. Based on this initial feedback, ICANN is developing an initial proposal for discussion based on the proposed "Option 1." We aim to have this ready for continued IRT discussions in late May. As a reminder, our IRT meeting for next week, 9 May, is canceled due to the GDD Summit. We will re-convene on 16 May. 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 www.icann.org

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Re: [Gdd-gnso-ppsai-impl] Accreditation and de-accreditation of NA-TPPPs
by Chris Pelling April 30, 2017

April 30, 2017

All very good points Theo, food for thought certainly. Sent from Chris on the move! On Sun, Apr 30, 2017 at 6:41 PM +0100, "theo geurts" <gtheo(a)xs4all.nl> wrote: Hi all, I think we are jumping the gun when it comes to the de-accreditation approach as proposed by the poll from last week. While trying to come up with a process, it became rather messy, and eventually, I gave up, as every solution was rather poor. So I reversed the process and started with the accreditation process to see if that would yield better results. The process for registrars offering privacy services or its affiliates is not problematic as we roughly have an idea and we have the WG recommendations. Now the non-affiliated third party privacy providers (NA-TPPP), that is a rather different beast. A classic example for those who spend time in the data metrics policy making WG where you can't qualify or quantify a problem, and you can't turn to the CPH to ask them for information or input due to the fact these TPPP are not regulated at all. NA-TPPP who or what are they? Some of them seem to be on the surface semi-professional while others seem to be a hobby project that grown out of portion and the rest is somewhere in between. The business model they use: You give them your registrant data, and they give you a set of privacy information that you can use at your registrar for free. One has to wonder how sustainable this business model is. How to onboard an NA-TPPP? For Registrars it is easy to get ICANN accredited in a sense, there is a good reason. A Registrar wants to register .com domain names? Then the requirement is to become ICANN accredited and only then you can start the accreditation process with Verisign. Onboarding an NA-TPPPs sounds like selling ice cream on the north pole. We barely have an idea who they are, and for sure they have no idea who or what ICANN is (sorry if I am bursting some bubbles here). Outreach will be problematic. Fees. NA-TPPPs do not sell domain names, they "offer" a service. For every registration and renewal a Registrar pays 18 cents to ICANN, wich goes into the ICANN budget. RDE Though the NA-TTTP might (it better be) have the registrant data, the Registrar is not included in this escrow deposit as they do not know where the privacy service info is used by the registrant. WDRP Audit requirement, who is going to pay for this? ERRP See WDRP ICANN involvement when NA-TPPP goes out of business. Worst case scenario the NA-TPPP gets breached and loses all data and backups. This has happened before in the past. ICANN would have to reach out to all registrants and somehow get Registrars in the mix. I am not sure how this scenario would unfold. Most likely it will be a costly business. Operational concerns IRTP C. This discussion still needs to take place somewhere. But if an NA-TPPP goes down we need to make sure that there is no loss of domain names or exposure of personal data. I think I am going to stop here for now. But I think we still need to get the accreditation process done first and then move on to the de-accreditation part. Best regards, Theo Geurts

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Accreditation and de-accreditation of NA-TPPPs
by theo geurts April 30, 2017

April 30, 2017

Hi all, I think we are jumping the gun when it comes to the de-accreditation approach as proposed by the poll from last week. While trying to come up with a process, it became rather messy, and eventually, I gave up, as every solution was rather poor. So I reversed the process and started with the accreditation process to see if that would yield better results. The process for registrars offering privacy services or its affiliates is not problematic as we roughly have an idea and we have the WG recommendations. Now the non-affiliated third party privacy providers (NA-TPPP), that is a rather different beast. A classic example for those who spend time in the data metrics policy making WG where you can't qualify or quantify a problem, and you can't turn to the CPH to ask them for information or input due to the fact these TPPP are not regulated at all. *NA-TPPP who or what are they?* Some of them seem to be on the surface semi-professional while others seem to be a hobby project that grown out of portion and the rest is somewhere in between. *The business model they use:* You give them your registrant data, and they give you a set of privacy information that you can use at your registrar for free. One has to wonder how sustainable this business model is. *How to onboard an NA-TPPP?* For Registrars it is easy to get ICANN accredited in a sense, there is a good reason. A Registrar wants to register .com domain names? Then the requirement is to become ICANN accredited and only then you can start the accreditation process with Verisign. Onboarding an NA-TPPPs sounds like selling ice cream on the north pole. We barely have an idea who they are, and for sure they have no idea who or what ICANN is (sorry if I am bursting some bubbles here). Outreach will be problematic. *Fees. * NA-TPPPs do not sell domain names, they "offer" a service. For every registration and renewal a Registrar pays 18 cents to ICANN, wich goes into the ICANN budget. *RDE* Though the NA-TTTP might (it better be) have the registrant data, the Registrar is not included in this escrow deposit as they do not know where the privacy service info is used by the registrant. *WDRP* Audit requirement, who is going to pay for this? *ERRP* See WDRP *ICANN involvement when NA-TPPP goes out of business. * Worst case scenario the NA-TPPP gets breached and loses all data and backups. This has happened before in the past. ICANN would have to reach out to all registrants and somehow get Registrars in the mix. I am not sure how this scenario would unfold. Most likely it will be a costly business. *Operational concerns* IRTP C. This discussion still needs to take place somewhere. But if an NA-TPPP goes down we need to make sure that there is no loss of domain names or exposure of personal data. I think I am going to stop here for now. But I think we still need to get the accreditation process done first and then move on to the de-accreditation part. Best regards, Theo Geurts

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Re: [Gdd-gnso-ppsai-impl] IRT poll deadline extended to 3 MAY; 2 MAY IRT meeting canceled
by Amy Bivins April 27, 2017

April 27, 2017

Dear Colleagues, Please note that references to “April” in the subject line and note below should be “May.” 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 www.icann.org From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, April 27, 2017 9:39 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] IRT poll deadline extended to 3 April; 2 April IRT meeting canceled Hi Darcy and all, Yes, certainly. Everyone, please complete this survey no later than your end of day next Wednesday, April 3. Thank you for your participation and contribution. So far, we have 9 responses that show a clear preference among IRT members to use “option 1” as a starting point in designing the de-accreditation process. Also, next week’s IRT meeting, scheduled for 2 May, will be canceled because we do not have new materials prepared to discuss. I regret that this will result in cancellations two weeks in a row (our meeting on 9 May is canceled due to the GDD Summit), but the break will allow time to ensure we have materials ready to discuss at our next meeting, scheduled for 16 May. Calendar updates will be distributed separately. I apologize for any inconvenience. When we re-convene in mid-May, we expect to be discussing the PSWG proposal, as soon as the PSWG is able to distribute it to the IRT. We will also discuss proposals on accreditation criteria/processes and de-accreditation following the initial IRT discussions, and we expect that we will be able to begin discussing the accreditation agreement shortly, as well. 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> From: gdd-gnso-ppsai-impl-bounces(a)icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Darcy Southwell Sent: Wednesday, April 26, 2017 3:24 AM To: gdd-gnso-ppsai-impl(a)icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] IRT Member Poll Re: De-Accreditation: Please Complete by EOD 28 April Thanks, Theo. I appreciate your suggestion and agree with you about adding option #3 and #4 to the survey. @Amy, I think it would be helpful if you could give us more than 3 days to complete the survey. Can we leave this open for at least a week? Darcy From: <gdd-gnso-ppsai-impl-bounces(a)icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> > on behalf of gtheo <gtheo(a)xs4all.nl <mailto:gtheo@xs4all.nl> > Reply-To: <gdd-gnso-ppsai-impl(a)icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> > Date: Wednesday, April 26, 2017 at 12:49 PM To: <gdd-gnso-ppsai-impl(a)icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> > Subject: Re: [Gdd-gnso-ppsai-impl] IRT Member Poll Re: De-Accreditation: Please Complete by EOD 28 April Hi Amy, I am struggling a little with this poll in the sense of committing to it. The mentioned principles recommended by the WG are fine. But the two possible options that ICANN sees as solutions are by no means complete. I appreciate the speediness of staff, but we are talking bout registrants here and procedures and how that will affect them. Option 1 looks like a path forward but requires a lot of work in the sense of getting it right. Option 2 looks not practical, as this procedure applies to registrars and not privacy providers. Making this work will also require a lot of work. Option 3? Work on option 1 and use it as a starting point and develop a framework and map out the actors and the possible scenarios. We will run into a lot of practical issues here, like for example is a 30 days notice enough and how are bounces being dealt with? This looks simple, but it will get complex fast. Option 4, other solutions? Thanks, Theo Amy Bivins schreef op 2017-04-25 06:16 PM: Dear Colleagues, Pursuant to our discussion on the Privacy/Proxy IRT call today, please complete the following one-question survey NO LATER THAN YOUR END OF DAY FRIDAY, 28 APRIL, 2017, https://www.surveymonkey.com/r/3D8F2B5 The introduction to the survey includes the background that was provided on the call. I encourage those who could not attend to also listen to the recording before answering the survey. The recording and other meeting materials are available on the wiki, https://community.icann.org/display/IRT/25+April+2017. Thank you for your participation on the call today and also on this poll. We need all of you to participate to ensure we have a clear view of your opinions on this topic. Details about next week's IRT meeting will be provided 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> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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IRT poll deadline extended to 3 April; 2 April IRT meeting canceled
by Amy Bivins April 27, 2017

April 27, 2017

Hi Darcy and all, Yes, certainly. Everyone, please complete this survey no later than your end of day next Wednesday, April 3. Thank you for your participation and contribution. So far, we have 9 responses that show a clear preference among IRT members to use “option 1” as a starting point in designing the de-accreditation process. Also, next week’s IRT meeting, scheduled for 2 May, will be canceled because we do not have new materials prepared to discuss. I regret that this will result in cancellations two weeks in a row (our meeting on 9 May is canceled due to the GDD Summit), but the break will allow time to ensure we have materials ready to discuss at our next meeting, scheduled for 16 May. Calendar updates will be distributed separately. I apologize for any inconvenience. When we re-convene in mid-May, we expect to be discussing the PSWG proposal, as soon as the PSWG is able to distribute it to the IRT. We will also discuss proposals on accreditation criteria/processes and de-accreditation following the initial IRT discussions, and we expect that we will be able to begin discussing the accreditation agreement shortly, as well. 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 www.icann.org From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Darcy Southwell Sent: Wednesday, April 26, 2017 3:24 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] IRT Member Poll Re: De-Accreditation: Please Complete by EOD 28 April Thanks, Theo. I appreciate your suggestion and agree with you about adding option #3 and #4 to the survey. @Amy, I think it would be helpful if you could give us more than 3 days to complete the survey. Can we leave this open for at least a week? Darcy From: <gdd-gnso-ppsai-impl-bounces(a)icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> > on behalf of gtheo <gtheo(a)xs4all.nl <mailto:gtheo@xs4all.nl> > Reply-To: <gdd-gnso-ppsai-impl(a)icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> > Date: Wednesday, April 26, 2017 at 12:49 PM To: <gdd-gnso-ppsai-impl(a)icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> > Subject: Re: [Gdd-gnso-ppsai-impl] IRT Member Poll Re: De-Accreditation: Please Complete by EOD 28 April Hi Amy, I am struggling a little with this poll in the sense of committing to it. The mentioned principles recommended by the WG are fine. But the two possible options that ICANN sees as solutions are by no means complete. I appreciate the speediness of staff, but we are talking bout registrants here and procedures and how that will affect them. Option 1 looks like a path forward but requires a lot of work in the sense of getting it right. Option 2 looks not practical, as this procedure applies to registrars and not privacy providers. Making this work will also require a lot of work. Option 3? Work on option 1 and use it as a starting point and develop a framework and map out the actors and the possible scenarios. We will run into a lot of practical issues here, like for example is a 30 days notice enough and how are bounces being dealt with? This looks simple, but it will get complex fast. Option 4, other solutions? Thanks, Theo Amy Bivins schreef op 2017-04-25 06:16 PM: Dear Colleagues, Pursuant to our discussion on the Privacy/Proxy IRT call today, please complete the following one-question survey NO LATER THAN YOUR END OF DAY FRIDAY, 28 APRIL, 2017, https://www.surveymonkey.com/r/3D8F2B5 The introduction to the survey includes the background that was provided on the call. I encourage those who could not attend to also listen to the recording before answering the survey. The recording and other meeting materials are available on the wiki, https://community.icann.org/display/IRT/25+April+2017. Thank you for your participation on the call today and also on this poll. We need all of you to participate to ensure we have a clear view of your opinions on this topic. Details about next week's IRT meeting will be provided 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> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl

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IRT Member Poll Re: De-Accreditation: Please Complete by EOD 28 April
by Amy Bivins April 26, 2017

April 26, 2017

Dear Colleagues, Pursuant to our discussion on the Privacy/Proxy IRT call today, please complete the following one-question survey no later than your end of day Friday, 28 April, 2017, https://www.surveymonkey.com/r/3D8F2B5 The introduction to the survey includes the background that was provided on the call. I encourage those who could not attend to also listen to the recording before answering the survey. The recording and other meeting materials are available on the wiki, https://community.icann.org/display/IRT/25+April+2017. Thank you for your participation on the call today and also on this poll. We need all of you to participate to ensure we have a clear view of your opinions on this topic. Details about next week's IRT meeting will be provided 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 www.icann.org

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Draft Language
by Darcy Southwell April 25, 2017

April 25, 2017

Hi, Amy. At the very end of today’s call, Steve Metalitz asked a question in the chat that I think you answered at the very end: steve metalitz: Staff, assuming you get further guidance through a poll or otherwise, when could we expect t see a specific proposal with draft language? *** Amy Bivins 2: Re: Steve, we could draft language for either quickly, but will have questions re: specifics to discuss I think we all realize that questions and discussions will come from the draft language, but I think they will be far more productive if we have draft language to discuss (rather than theoretical concepts). I would encourage staff to draft a proposal based on the PDP recommendations. Then we can have material conversations about how this program. Thanks, Darcy ---------------- Darcy Southwell | Compliance Officer M: +1 503-453-7305 │ Skype: darcy.enyeart

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Recap of 18 April Privacy/Proxy IRT meeting, agenda for 25 April
by Amy Bivins April 20, 2017

April 20, 2017

Dear Colleagues, Thanks again for a very productive discussion on our Privacy/Proxy IRT call this week. I'm attaching a summary document of the input we received from you related to the PP provider accreditation process. The call recording, slides and attendance list are available on the wiki, https://community.icann.org/display/IRT/18+April+2017. The main takeaways from this meeting are as follows: 1. IRT members recommended that ICANN should not limit eligibility for privacy/proxy providers to apply for accreditation in an initial application round at the outset of the program. Thus, if there is an initial applicant round, any provider should be eligible to apply, regardless of whether the provider is affiliated with a registrar. 2. ICANN should consider streamlining the application process for registrar-affiliated privacy/proxy providers, possibly by not requiring those providers to answer questions about/demonstrate understanding of requirements that the registrar is already required to comply with pursuant to the RAA. 3. ICANN should require providers to complete a training course/exam as a condition to (before) obtaining accreditation. Next Steps On This Topic The ICANN organization will complete work on proposed accreditation criteria/processes, in light of the IRT's feedback, to present to the IRT for discussion. Other Action Items IRT members asked a few questions that could not be answered during the meeting, including: (1) What is the current volume of registrar accreditation applications processed by ICANN? (2) How many applications for accreditation did ICANN receive at the launch of the registrar accreditation program? Answers are as follows: (1) ICANN received 9-12 applications/quarter in each of the last three quarters if you do not count the bulk accreditations received (counting each in a bulk accreditation batch as 1 application). (2) In our first announcement on the registrar accreditation program, on 21 April 1999, ICANN announced that 34 companies had applied and met the accreditation criteria <https://www.icann.org/news/icann-pr-1999-04-21-en>. By the end of 1999 ICANN had announced a total of 98 applicants that met the criteria <https://www.icann.org/news/icann-pr-1999-12-21-en>. ICANN announced in May 2000 that we were up to 124 companies <https://www.icann.org/news/icann-pr-2000-05-11-en>. Next IRT Meeting The IRT's next meeting is scheduled for this upcoming Tuesday, 25 April, at 1400 UTC. The calendar reminder will be distributed separately. On this call, we will discuss the registrar de-accreditation process. Caitlin Tubergen, who manages this process for the Registrar Services & Engagement Team, will be with us on the call. A description of the process is available at, https://www.icann.org/resources/files/dartp-2013-07-11-en. As this process was referenced by the PDP WG, we want to provide a quick primer on the process for the IRT, and then we will discuss possible challenges to applying this process in the Privacy/Proxy context. The goal of the call is to solicit the IRT's views on how this process should-or should not-be applied to privacy/proxy providers. If you have questions, please don't hesitate to contact me or reply to the list. Best, 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 www.icann.org

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Pirate Bay Founder to offer Anonymous Domain Registration Service
by Carlton Samuels April 20, 2017

April 20, 2017

Privacy....with a twist. https://torrentfreak.com/pirate-bay-founder-launches-anonymous-domain-regis… -Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Planning, Governance, Assessment & Turnaround* ============================= > >

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PPSAI IRT call today ?
by Metalitz, Steven April 19, 2017

April 19, 2017

Sorry if I have missed it but does the PPSAI IRT have a call today and if so what is the agenda? Thanks. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.

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Re: [Gdd-gnso-ppsai-impl] [Ntfy-gdd-gnso-ppsai-impl] REMINDER: Privacy and Proxy Services Accreditation Program IRT CALL ON IN 20 minutes at 14:00 UTC
by Amy Bivins April 18, 2017

April 18, 2017

Hi Steve, We have a short agenda today-we are only discussing one topic: the accreditation process. 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 www.icann.org From: Metalitz, Steven [mailto:met@msk.com] Sent: Tuesday, April 18, 2017 9:50 AM To: Michelle DeSmyter <michelle.desmyter(a)icann.org> Cc: Amy Bivins <amy.bivins(a)icann.org> Subject: [Ext] RE: [Ntfy-gdd-gnso-ppsai-impl] REMINDER: Privacy and Proxy Services Accreditation Program IRT CALL ON IN 20 minutes at 14:00 UTC Thanks Michelle. Can you circulate the agenda please? Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | <mailto:met@msk.com> met(a)msk.com Mitchell Silberberg & Knupp LLP | <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.msk.com_&d=DwMF-g&c =FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgt dWrvLyZDu0mXuk&m=G6p4KbYSFeLF-elVJ0y8mX_95dvlTA95VJNN2uPe2Cs&s=i3MucG_J_BcVO CrFuZC3NvW7Q8EGuhHdpL7DFZqqOfo&e=> www.msk.com[msk.com] 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: ntfy-gdd-gnso-ppsai-impl-bounces(a)icann.org <mailto:ntfy-gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:ntfy-gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Michelle DeSmyter Sent: Tuesday, April 18, 2017 9:45 AM To: ntfy-gdd-gnso-ppsai-impl(a)icann.org <mailto:ntfy-gdd-gnso-ppsai-impl@icann.org> Subject: [Ntfy-gdd-gnso-ppsai-impl] REMINDER: Privacy and Proxy Services Accreditation Program IRT CALL ON IN 20 minutes at 14:00 UTC Dear Colleagues, Please find below the remote participation details for the Privacy and Proxy Services Accreditation Program IRT Meetings which will be held on Tuesday, 18 April 2017 at 14:00 UTC for 1 hour 30 minutes. Adobe Connect link: <https://participate.icann.org/ppirt> https://participate.icann.org/ppirt Participant code: 4824695647 Dial-In Phone Numbers: US: +1-719-457-6209 Canada, Calgary: +1 403 407 5793 Canada, Montreal: +1 514 669 5928 Canada, Toronto: +1 647 426 9172 Canada, Vancouver: +1 604 222 7836 Argentina (toll free): 0800 800 1223 Argentina, Buenos Aires: +54 (0) 11 5172 6003 Australia (toll free): 1 800 804 786 Australia, Brisbane: +61 (0) 7 3015 0535 Australia, Melbourne: +61 (0) 3 8687 0553 Australia, Sydney: +61 (0) 2 8017 6064 Austria (toll free): 0800 8866 3413 Austria, Vienna: +43 (0) 1 25302 1785 Bahrain (toll free): 800 04212 Bahrain, Manama: +973 1619 8739 Belarus (toll free): 8 820 0011 0341 Belgium (toll free): 0800 39279 Belgium, Brussels: +32 (0) 2 400 6928 Brazil (toll free): 0800 887 0233 Brazil, Rio de Janeiro: +55 21 4560 0072 Brazil, Sao Paulo: +55 11 4935 7169 Bulgaria (toll free): 00800 111 4950 Bulgaria, Sofia: +359 (0) 2 491 6045 Canada (toll free): 1 855 950 3717 Chile (toll free): 171 800 835 783 Chile, Santiago: +56 (0) 2 2666 0696 China (national): +400 613 8103 China, Beijing: +86 10 5667 0003 China, Shanghai: +86 21 2039 7081 Colombia (toll free): 01 800 755 0102 Colombia, Bogota: +57 1 508 8137 Croatia (toll free): 0800 805 940 Cyprus (toll free): 800 97424 Czech Republic (toll free): 800 701 532 Czech Republic, Prague: +420 225 986 554 Denmark (toll free): 80 70 35 86 Denmark, Copenhagen: +45 32 72 78 10 Egypt (toll free): 0800 000 0593 Estonia (toll free): 800 011 1589 Estonia, Tallinn: +372 622 6551 Fiji (toll free): 00800 3322 Finland (toll free): 0800 772 236 Finland, Helsinki: +358 (0) 9 2310 1677 France (national): 0811 655 100 France (toll free): 0800 946 531 France, Paris: +33 (0) 1 70 37 16 56 Germany (national): 01801 003 899 Germany (toll free): 0800 588 9170 Germany, Frankfurt: +49 (0) 69 2222 10612 Germany, Munich: +49 (0) 89 2030 31207 Greece (toll free): 00800 128 913 Greece, Athens: +30 211 181 3824 Hong Kong: +852 3018 9111 Hong Kong (toll free): 800 901 787 Hungary (toll free): 068 001 9673 Hungary, Budapest: +36 1408 8953 Iceland (toll free): 800 9847 India, Bangalore: +91 (0) 80 6127 6710 India, Chennai: +91 (0)44 6688 6061 India, Delhi: +91 (0) 11 6641 1394 India, Mumbai: +91 (0)22 6187 5028 Indonesia (toll free): 007 803 321 8927 Ireland (national): 1890 907 630 Ireland (toll free): 1800 937 649 Ireland, Dublin: +353 (0) 1 526 9421 Israel (toll free): 1809 213 168 Israel, Tel Aviv: +972 (0)3 721 7943 Italy (toll free): 800 146 094 Italy, Milan: +39 02 3600 8006 Italy, Rome: +39 06 8750 0676 Japan (mobile): 0120 632 611 Japan (toll free): 0120 305 211 Japan, Osaka: +81 (0) 6 4560 2410 Japan, Tokyo: +81 (0) 3 4560 1270 Kazakhstan (toll free): 8800 333 7554 Latvia (toll free): 8000 4418 Latvia, Riga: +371 6601 3627 Lithuania (toll free): 8800 31449 Lithuania, Vilnius: +370 5205 5468 Luxembourg: +352 2088 1749 Luxembourg (toll free): 800 28433 Malaysia (toll free): 1 800 816 152 Malaysia,Kuala Lumpur: +60 (0) 3 7724 8010 Mexico (toll free): 01 800 733 4102 Mexico, Guadalajara: +52 33 4162 4504 Mexico, Mexico City: +52 55 8421 0326 Mexico, Monterrey: +52 81 4162 5648 Morocco (toll free): 0800 091 296 Morocco, Casablanca: +212 (0) 520 48 0022 Netherlands (toll free): 0800 020 2597 Netherlands, Amsterdam: +31 (0) 20 716 8345 New Zealand (toll free): 0800 452 947 New Zealand, Auckland: +64 (0) 9 929 1825 New Zealand, Christchurch: +64 (0) 3 974 2596 New Zealand, Wellington: +64 (0) 4 909 4674 Nigeria, Lagos: +234 1 277 3944 Norway (toll free): 800 56081 Norway, Oslo: +47 21 00 48 15 Panama (toll free): 00800 223 1390 Panama, Panama City: +507 8 335 913 Peru, Lima: +51 (0) 1 700 9571 Philippines (toll free): 1 800 111 013 99 Philippines, Manila: +63 (0)2 395 3426 Poland (toll free): 00 800 121 4356 Poland, Warsaw: +48 22 295 3570 Portugal (toll free): 800 784 442 Portugal, Lisbon: +351 21 316 4093 Qatar (toll free): 00 800 100 491 Romania (toll free): 0800 801 035 Romania, Bucharest: +40 (0) 21 529 3992 Russia (toll free): 8 800 500 9241 Russia, Moscow: +7 495 646 9181 Saudi Arabia (toll free): 800 844 6641 Saudi Arabia (toll free): 800 850 0219 Singapore: +65 6622 1957 Singapore (toll free): 800 616 3192 Slovakia (toll free): 0800 002 002 Slovakia, Bratislava: +421 (0)2 3321 5498 Slovenia (toll free): 0800 81193 Slovenia, Ljubljana: +386 1600 8695 South Africa (toll free): 0800 999 434 South Africa, Johannesburg: +27 (0)11 589 8321 South Korea (toll free): 00798 6136 1454 South Korea, Seoul: +82 (0) 2 6007 0079 Spain (toll free): 900 828 035 Spain, Barcelona: +34 93 800 1946 Spain, Madrid: +34 91 114 6653 Sweden (toll free): 0200 125 588 Sweden, Stockholm: +46 (0) 8 5065 3956 Switzerland (toll free): 0800 740 360 Switzerland, Geneva: +41 (0) 22 595 4795 Switzerland, Zurich: +41 (0) 44 580 7207 Taiwan (toll free): 0800 666 596 Taiwan, Taipei: +886 (0) 2 2650 7329 Thailand (toll free): 001 800 6136 1473 Turkey (toll free): 00800 4488 26642 Turkey, Istanbul: +90 212 375 50 49 UAE (toll free): 8000 3570 2662 UK (03): +44 (0)330 336 6002 UK (toll free): 0800 358 6385 Ukraine (toll free): 0800 500 896 Uruguay (toll free): 0004 019 0152 USA /Canada (toll free): 1-866-398-2885 Venezuela (toll free): 0 800 162 7451 Vietnam (toll free): 1800 9226 Costa Rica (toll free): 800 542 5328 France (national): 0821 231 671 India (toll free): 1800 200 9415 Indonesia, Jakarta: +62 21 2188 9084 Ireland (national): 0818 270 271 Japan (national): 0570 085 744 Serbia (toll free): 0800 190 712 UK (national): 0844 473 5010 UK (national): 0845 545 0015 Venezuela, Caracas: +58 212 720 2164

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Agenda for 11 April 2017 Privacy/Proxy IRT meeting, 1400 UTC
by Amy Bivins April 11, 2017

April 11, 2017

Dear Colleagues, At the next Privacy/Proxy Service Provider Accreditation IRT meeting, scheduled for 11 April 2017, 1400 UTC, we will have a follow-up discussion on two topics we have discussed previously: * Whether registrars should authenticate accredited privacy/proxy providers that are not affiliated with the registrar; and * Registration Data Directory Service (RDDS) labeling requirements. Because we want to discuss these topics from a technical standpoint, Francisco Arias, Sr. Director, GDD Technical Services, will be with us on the call. Our goal is to ensure that our implementation with respect to these topics is consistent with the intent of the Policy Recommendations and technically sound. We initially discussed the possibility of requiring registrars to authenticate unaffiliated privacy/proxy providers during our face-to-face meeting at ICANN58 as a way to implement the recommendation "Registrars are not to knowingly accept registrations from privacy or proxy service providers who are not accredited through the process developed by ICANN." A summary of your input on this topic is attached. A requirement that a registrar authenticate that an entity that presents itself as an accredited provider is, in fact, an accredited provider, would provide certainty in the overall marketplace. We would like to discuss our reasoning with you further and solicit your feedback. As you may recall, we first discussed RDDS labeling on our 14 February IRT call. During that meeting we discussed an ICANN-organization proposal for new RDDS fields for registrations involving privacy/proxy services. A summary of your input on this topic is attached. We would like to discuss potential technical reasons why at least one new field could be a more viable alternative for RDDS users to using existing fields and possible challenges to using existing fields. We look forward to a robust discussion and hope you can participate. Our goal is to reach agreement on these topics by the close of the call. If you have questions or comments beforehand, please send them to the list. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Agenda for Privacy/Proxy IRT call tomorrow, 14:00 UTC
by Amy Bivins April 4, 2017

April 4, 2017

Hi, All, This is a reminder of the Privacy/Proxy IRT meeting scheduled for tomorrow at 14:00 UTC. Our agenda is as follows: * IRT feedback on draft Policy document (no feedback received on list as of now) * Abuse report criteria (follow-up on discussion at ICANN58 and last week's IRT member poll) o Definition of "abuse" o Criteria for submitting abuse report o Required Provider actions upon receiving abuse report * Relay criteria (follow-up on discussion at ICANN58 and last week's IRT member poll) o Should "abuse" for Relay option 2 be defined consistently with abuse reporting criteria? o Should Providers be required to test that relay is working properly? o Should there be a required timeframe for mandatory relay? I hope you are well and look forward to speaking with you tomorrow. If anyone would like to share feedback on the draft Policy document before the call on-list, please do. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Link to Privacy/Proxy IRT survey, summary of input at ICANN58, next steps
by Amy Bivins March 28, 2017

March 28, 2017

Hello, All, I hope you are well, and that those of you who attended ICANN58 had a safe journey home. Thanks so much for participating in our discussion on 11 March. I think we made a lot of progress. I have attached two documents that include detailed summaries of the input received during the session (apologies for any typos, I was typing this quickly while listening to the recording). In order to ensure we have a full representation of the IRT's views on these topics (since not everyone was at ICANN58) we are asking you to please complete this survey no later than 28 March, https://goo.gl/forms/F5DnAmd4W7upuLPG3. This survey includes many of the questions that were asked during the session at ICANN 58, and refers back to specific pages in the summary documents if you would like additional background or more information about what was said during the session. The session recording and slides are available on the wiki, https://community.icann.org/display/IRT/11+March+2017--ICANN+58. We are planning to meet next week, 28 March, and hope to be ready to distribute the updated draft Policy document for discussion. If for some reason the document cannot be ready for discussion next week, I'll let you know by the end of this week. If you have any questions or comments, please don't hesitate to contact me or reply to the list. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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[For Discussion on IRT call tomorrow] Full Privacy/Proxy Accreditation Policy, IRT review version v1
by Amy Bivins March 27, 2017

March 27, 2017

Hi All, Apologies for the late distribution--the draft privacy/proxy accreditation policy document is attached, for a brief introductory discussion on our IRT call tomorrow (at 1500 UTC). Our call tomorrow will be extremely brief-I want to quickly explain the changes that have been made to this document since we discussed the first version of the Policy outline (you'll notice this document is significantly shorter). After that, we will adjourn to give you time to thoroughly review the document for a full discussion next week. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Agenda, questions for Privacy/Proxy IRT meeting on 11 March
by Amy Bivins March 10, 2017

March 10, 2017

Hello, All, I hope you are well, and I look forward to seeing those of you who are attending our face-to-face meeting in Copenhagen on Saturday. As a reminder, our meeting will be in Hall A3 and will start at 13:45 local time. We have the room reserved until 18:00. Remote participation will be available here: https://schedule.icann.org/event/9nnx/icann-gdd-privacy-and-proxy-service-pr ovider-accreditation-program-implementation-review-team-irt Our agenda is as follows (we will follow this as closely as we can): Part 1: 13:45-15:00: Timeline Check, Updated Policy Document Overview, Third-Party Requests/Abuse Reports * See attachment: IRT questions related to criteria for third-party requests and abuse reports 15:00-15:15: Break Part 2: 15:15-16:45: Public Safety Working Group Discussion, Questions related to Accreditation Agreement 16:45-17:00: Break Part 3: 17:00-18:00: Registrar-related questions * During this final time slot, we will discuss registrar-related questions that have arisen thus far in this IRT: (1) How do you envision the registration lifecycle operating when a Provider is not Affiliated with a Registrar (topic is being raised now due to its impact on other requirements, including labeling)? (2) What should a registrar be required to do when it becomes aware of a registration involving an unaccredited Provider? Alternatives previously raised for discussion included: o Registrar could treat situation as a WHOIS accuracy issue and verify/re-verify email address (this may not reach root issue because email may be operational); o Registrar could be required to notify unaccredited Provider of requirement that Providers maintain ICANN accreditation, and provide Provider/Customer a period of time to remedy situation before suspending registration; o In all cases, should allow significant period for onboarding Providers before enforcing this requirement. If you have questions or wish to comment prior to the meeting, please feel free to do so on the list. Safe travels! Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Privacy/Proxy Service Provider Accreditation IRT Meeting at ICANN58
by Amy Bivins March 10, 2017

March 10, 2017

Dear Colleagues, You are cordially invited to attend the Privacy and Proxy Service Provider Accreditation Program IRT meeting at ICANN 58, scheduled for 11 March 2017, 13:45-18:00 local time (12:45-17:00 UTC) in Hall A3. This session is open to the public, but this is a working meeting of the IRT. A detailed agenda and relevant materials will be distributed to the IRT prior to the meeting. Remote participation information is as follows: * Adobe Connect https://participate.icann.org/cph58-halla3 * English Audio (Low Bitrate) http://stream.icann.org:8000/cph58-halla3-en-lo.m3u * English Audio http://stream.icann.org:8000/cph58-halla3-en.m3u Dial-in numbers for the phone bridge are below. There will be audio enabled in Adobe Connect, but if you would prefer to dial in separately you can use these numbers. Best, Amy Amy E. Bivins Registrar Policy Services 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> __________________________________________________________________ You're Invited. You've been invited to a GlobalMeet® phone only meeting. Have the meeting call you. Click the Connect Me link below. No need to dial-in. Connect Me <https://go.conferencinghub.com/2kty5> Not at your computer? You can join by dialing one of the access numbers below. Mobile: tel://1-719-457-6209,*,,4824695647# Phone Only Controls: https://go.conferencinghub.com/2kty5 Primary Access Number: 1-719-457-6209 Guest Passcode: 482 469 5647 Additional Access: USA 1-719-457-6209 Canada, Calgary +1 403 407 5793 Canada, Montreal +1 514 669 5928 Canada, Toronto +1 647 426 9172 Canada, Vancouver +1 604 222 7836 Argentina (toll free) 0800 666 2649 Australia (toll free) 1 800 804 786 Australia, Brisbane +61 (0) 7 3015 0535 Australia, Melbourne +61 (0) 3 8687 0553 Australia, Sydney +61 (0) 2 8017 6064 Austria (toll free) 0800 8866 3413 Austria, Vienna +43 (0) 1 25302 1785 Bahrain (toll free) 800 04212 Bahrain, Manama +973 1619 8739 Belarus (toll free) 8 820 0011 0341 Belgium (toll free) 0800 39279 Belgium, Brussels +32 (0) 2 400 6928 Brazil, Rio de Janeiro +55 21 2730 6944 Brazil, Sao Paulo +55 11 3351 7036 Bulgaria (toll free) 00800 111 4950 Bulgaria, Sofia +359 (0) 2 491 6045 Chile (toll free) 800 363 514 China (national) +400 613 8103 China, Beijing +86 10 5667 0003 China, Shanghai +86 21 2039 7081 Colombia (toll free) 01 800 518 0646 Croatia (toll free) 0800 805 940 Cyprus (toll free) 800 97424 Czech Republic (toll free) 800 701 532 Czech Republic, Prague +420 225 986 554 Denmark (toll free) 80 70 35 86 Denmark, Copenhagen +45 32 72 78 10 Egypt (toll free) 0800 000 0593 Estonia (toll free) 800 011 1589 Estonia, Tallinn +372 622 6551 Finland (toll free) 0800 772 236 Finland, Helsinki +358 (0) 9 2310 1677 France (national) 0811 655 100 France (toll free) 0800 946 531 France, Paris +33 (0) 1 70 37 16 56 Germany (national) 01801 003 899 Germany (toll free) 0800 588 9170 Germany, Frankfurt +49 (0) 69 2222 10612 Germany, Munich +49 (0) 89 2030 31207 Greece (toll free) 00800 128 913 Greece, Athens +30 211 181 3824 Hong Kong +852 3018 9111 Hong Kong (toll free) 800 901 787 Hungary (toll free) 068 001 9673 Hungary, Budapest +36 1408 8953 Iceland (toll free) 800 9847 India (toll free) 000 800 1008 367 India (toll free) 1800 266 0376 India, Bangalore +91 (0) 80 6127 6710 India, Chennai +91 (0)44 6688 6061 India, Delhi +91 (0) 11 6641 1394 India, Mumbai +91 (0)22 6187 5028 Indonesia (toll free) 001 803 016 2541 Ireland (national) 1890 907 630 Ireland (toll free) 1800 937 649 Ireland, Dublin +353 (0) 1 526 9421 Israel (toll free) 1809 213 168 Israel, Tel Aviv +972 (0)3 721 7943 Italy (toll free) 800 146 094 Italy, Milan +39 02 3600 8006 Italy, Rome +39 06 8750 0676 Japan (mobile) 0120 632 611 Japan (toll free) 0120 305 211 Japan, Chiba +81 (0) 43 321 6881 Japan, Fukuoka +81 (0) 92 290 6881 Japan, Hiroshima +81 (0) 82 558 6881 Japan, Nagoya +81 (0) 52 850 6881 Japan, Osaka +81 (0) 6 4560 2410 Japan, Sapporo +81 (0) 11 234 6881 Japan, Sendai +81 (0) 22 708 6881 Japan, Shizuoka +81 (0) 54 902 6881 Japan, Tachikawa +81 (0) 42 841 6881 Japan, Tokyo +81 (0) 3 4560 1270 Japan, Toyama +81 (0) 76 408 6881 Japan, Urawa +81 (0) 48 698 6881 Japan, Yokohama +81 (0) 45 677 6881 Kazakhstan (toll free) 8800 333 7554 Latvia (toll free) 8000 4418 Latvia, Riga +371 6601 3627 Lithuania (toll free) 8800 31449 Lithuania, Vilnius +370 5205 5468 Luxembourg +352 2088 1749 Luxembourg (toll free) 800 28433 Malaysia (toll free) 1 800 816 152 Malaysia,Kuala Lumpur +60 (0) 3 7724 8010 Mexico (toll free) 01 800 054 0370 Mexico, Mexico City +52 55 4777 2658 Morocco (toll free) 0800 091 296 Morocco, Casablanca +212 (0) 520 48 0022 Netherlands (toll free) 0800 020 2597 Netherlands, Amsterdam +31 (0) 20 716 8345 New Zealand (toll free) 0800 452 947 New Zealand, Auckland +64 (0) 9 929 1825 New Zealand, Christchurch +64 (0) 3 974 2596 New Zealand, Wellington +64 (0) 4 909 4674 Norway (toll free) 800 56081 Norway, Oslo +47 21 00 48 15 Panama (toll free) 00 800 226 3770 Peru (toll free) 0800 55092 Philippines (toll free) 1 800 111 013 99 Philippines, Manila +63 (0)2 395 3426 Poland (toll free) 00 800 121 4356 Poland, Warsaw +48 22 295 3570 Portugal (toll free) 800 784 442 Portugal, Lisbon +351 21 316 4093 Romania (toll free) 0800 801 035 Romania, Bucharest +40 (0) 21 529 3992 Russia (toll free) 8 800 500 9241 Russia, Moscow +7 495 646 9181 Saudi Arabia (toll free) 800 844 6641 Singapore +65 6622 1957 Singapore (toll free) 800 616 3192 Slovakia (toll free) 0800 002 002 Slovakia, Bratislava +421 (0)2 3321 5498 Slovenia (toll free) 0800 81193 Slovenia, Ljubljana +386 1600 8695 South Africa (toll free) 0800 999 434 South Africa, Johannesburg +27 (0)11 589 8321 South Korea (toll free) 00798 6136 1454 South Korea, Seoul +82 (0) 2 6007 0079 Spain (toll free) 900 828 035 Spain, Barcelona +34 93 800 1946 Spain, Madrid +34 91 114 6653 Sweden (toll free) 0200 125 588 Sweden, Stockholm +46 (0) 8 5065 3956 Switzerland (toll free) 0800 740 360 Switzerland, Geneva +41 (0) 22 595 4795 Switzerland, Zurich +41 (0) 44 580 7207 Taiwan (toll free) 0800 666 596 Taiwan, Taipei +886 (0) 2 2650 7329 Thailand (toll free) 001 800 6136 1473 Turkey (toll free) 00800 4488 26642 Turkey, Istanbul +90 212 375 50 49 UAE (toll free) 8000 3570 2662 UK (national) 0844 581 8062 UK (national) 0845 351 2782 UK (toll free) 0800 358 6385 Ukraine (toll free) 0800 500 896 Uruguay (toll free) 0004 019 0152 USA /Canada (toll free) 1-866-398-2885 Venezuela (toll free) 0 800 162 7451 Vietnam (toll free) 1800 9226 Questions? Go to GlobalMeet Support<http://community.globalmeet.com> © Premiere Global Services, Inc. and/or its affiliates | PGi

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Privacy/Proxy Service Provider Accreditation IRT Meeting at ICANN58
by Amy Bivins March 1, 2017

March 1, 2017

Dear Colleagues, You are cordially invited to attend the Privacy and Proxy Service Provider Accreditation Program IRT meeting at ICANN 58, scheduled for 11 March 2017, 13:45-18:00 local time (12:45-17:00 UTC). This session is open to the public, but this is a working meeting of the IRT. A detailed agenda and relevant materials will be distributed to the IRT prior to the meeting. Remote participation information is as follows: * Adobe Connect https://participate.icann.org/cph58-halla3 * English Audio (Low Bitrate) http://stream.icann.org:8000/cph58-halla3-en-lo.m3u * English Audio http://stream.icann.org:8000/cph58-halla3-en.m3u Best, Amy Amy E. Bivins Registrar Policy Services 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] Agenda and discussion question for 28 February Privacy/Proxy IRT meeting
by Darcy Southwell Feb. 28, 2017

Feb. 28, 2017

Thanks, Amy. I find the second part of item 2 (after the word “so”) to be confusing and inconsistent with the PDP WG’s intent. Depending on what is considered to be “Customer data,” the discussion was never that registrars would no longer have to “retain” or “escrow” such data. Rather the WG’s focus was (as with many other processes that we’ve discussed so far) that accredited registrars should not have to duplicate work if they are also accredited P/P providers. If that’s what we’re trying to address with item #1, then we should probably rework the language a bit. Is there some clarity that can be provided here before our meeting? Generally speaking, I think item #2 seems at odds with the very concept of an accreditation program. Thanks, Darcy 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> Date: Friday, February 24, 2017 at 6:14 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda and discussion question for 28 February Privacy/Proxy IRT meeting Hello, All, I hope you are well! This is a reminder of the Privacy/Proxy Services Accreditation IRT call scheduled for 28 February 2017 at 15:00 UTC. I hope you can attend. Our agenda is fairly short, so the call will likely not last the full 90 minutes. Attached is a document that includes background material (text of relevant RAA provisions) and a discussion question for the call. I’m repeating the question here for convenience (if you wish to share your thoughts on this before Tuesday, please feel free to do so on the list): In light of existing RAA requirements for Registrars’ retention and escrow of Privacy and Proxy Service Customer data, and in light of the discussions during the 24th January 2017 Privacy/Proxy Implementation Review Team meeting, the ICANN organization should implement data escrow and retention requirements for accredited Privacy and Proxy Service Providers as follows (choose one): 1. The data escrow and retention requirements for Registrars (with respect to Privacy/Proxy Customer data) should be superseded by new requirements for all accredited Privacy and Proxy Service Providers, so that Registrars would no longer be required to retain or escrow the underlying Customer data associated with Privacy and Proxy Service registrations offered or made available by the Registrar or its affiliates; or 2. ICANN should permit the Registrar and the accredited Privacy and Proxy Service Provider to choose whether the Registrar or the Provider will be responsible for escrow and retention of Customer data. In addition to this question, we will also discuss potential topics for our agenda at our half-day meeting at ICANN58. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.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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Agenda and discussion question for 28 February Privacy/Proxy IRT meeting
by Winterfeldt, Brian J. Feb. 27, 2017

Feb. 27, 2017

Dear Amy and all: We would support the first of the two options below, namely: The data escrow and retention requirements for Registrars (with respect to Privacy/Proxy Customer data) should be superseded by new requirements for all accredited Privacy and Proxy Service Providers, so that Registrars would no longer be required to retain or escrow the underlying Customer data associated with Privacy and Proxy Service registrations offered or made available by the Registrar or its affiliates. We believe the second option would create inconsistency and confusion, particularly for third parties who would not immediately know whether to go to the registrar or the P/P service provider to obtain retained/escrowed customer data. We believe the accreditation policy/agreement should set one standard applicable across the board for who will retain/escrow customer data as between the registrar and P/P service provider, with the logical choice being the P/P provider because they are in direct contact with the customer whereas the registrar may only have the P/P service provider’s data as the de facto registrant. Best regards, Brian, Phil and Griffin Brian J. Winterfeldt Co-Head of Global Brand Management and Internet Practice Mayer Brown LLP bwinterfeldt(a)mayerbrown.com<mailto:bwinterfeldt@mayerbrown.com> 1999 K Street, NW Washington, DC 20006-1101 202.263.3284 direct dial 202.830.0330 fax 1221 Avenue of the Americas New York, New York 10020-1001 212.506.2345 direct dial From: gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Friday, February 24, 2017 9:15 AM To: gdd-gnso-ppsai-impl(a)icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda and discussion question for 28 February Privacy/Proxy IRT meeting Hello, All, I hope you are well! This is a reminder of the Privacy/Proxy Services Accreditation IRT call scheduled for 28 February 2017 at 15:00 UTC. I hope you can attend. Our agenda is fairly short, so the call will likely not last the full 90 minutes. Attached is a document that includes background material (text of relevant RAA provisions) and a discussion question for the call. I’m repeating the question here for convenience (if you wish to share your thoughts on this before Tuesday, please feel free to do so on the list): In light of existing RAA requirements for Registrars’ retention and escrow of Privacy and Proxy Service Customer data, and in light of the discussions during the 24th January 2017 Privacy/Proxy Implementation Review Team meeting, the ICANN organization should implement data escrow and retention requirements for accredited Privacy and Proxy Service Providers as follows (choose one): 1. The data escrow and retention requirements for Registrars (with respect to Privacy/Proxy Customer data) should be superseded by new requirements for all accredited Privacy and Proxy Service Providers, so that Registrars would no longer be required to retain or escrow the underlying Customer data associated with Privacy and Proxy Service registrations offered or made available by the Registrar or its affiliates; or 2. ICANN should permit the Registrar and the accredited Privacy and Proxy Service Provider to choose whether the Registrar or the Provider will be responsible for escrow and retention of Customer data. In addition to this question, we will also discuss potential topics for our agenda at our half-day meeting at ICANN58. Best, Amy Amy E. Bivins Registrar Policy Services 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> __________________________________________________________________________ This email and any files transmitted with it are intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. If you are not the named addressee you should not disseminate, distribute or copy this e-mail.

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Re: [Gdd-gnso-ppsai-impl] Agenda and discussion question for 28 February Privacy/Proxy IRT meeting
by Chris Pelling Feb. 24, 2017

Feb. 24, 2017

Whilst it might be a "great email" and thank you Amy for checking, I'll need to check if this meeting clashes with the EU Data commissioners coming to RDS, if it does, I may well have to be in the RDS meeting. Thanks, Chris Sent from Chris on the move! On Fri, Feb 24, 2017 at 6:02 PM +0000, "Jennifer Gore" <jennifer.gore(a)icann.org> wrote: Great email. That is all you can do... On Feb 24, 2017, at 12:58 PM, Amy Bivins <amy.bivins(a)icann.org> wrote: Hi Chris, Theo and All, This conflict is unfortunate, but I don’t think we can avoid it. I double-checked with Mary and there are multiple reasons why the WG meetings on Saturday are scheduled in this order, and they can’t be moved. I’ll post an agenda (with approximate times noted) for you ahead of time. And, in addition to posting all of the materials and the recordings, I’ll send around notes of key action items/points raised to ensure that anyone not in attendance can easily note significant developments. I hope this helps! Have a great weekend, everyone. Amy From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Chris Pelling Sent: Friday, February 24, 2017 11:07 AM To: gdd-gnso-ppsai-impl(a)icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Agenda and discussion question for 28 February Privacy/Proxy IRT meeting I agree with Theo here, this is rather problematic for those of us on both RDS and PPSAI, we could use the T.A.R.D.I.S. do PPSAI and go back to do RDS. :p Kind regards, Chris From: "theo geurts" <gtheo(a)xs4all.nl> To: gdd-gnso-ppsai-impl(a)icann.org Sent: Friday, 24 February, 2017 15:13:40 Subject: Re: [Gdd-gnso-ppsai-impl] Agenda and discussion question for 28 February Privacy/Proxy IRT meeting Hi Amy, This looks good, so we should be able to cover this pretty quick. ICANN 58. The RDS WG and the PPSAI IRT run in parallel on Saturday? Am I the only one who finds this slightly problematic? If there are cloning facilities at the venue, then there is no problem ;) Best Theo On 24-2-2017 15:14, Amy Bivins wrote: Hello, All, I hope you are well! This is a reminder of the Privacy/Proxy Services Accreditation IRT call scheduled for 28 February 2017 at 15:00 UTC. I hope you can attend. Our agenda is fairly short, so the call will likely not last the full 90 minutes. Attached is a document that includes background material (text of relevant RAA provisions) and a discussion question for the call. I’m repeating the question here for convenience (if you wish to share your thoughts on this before Tuesday, please feel free to do so on the list): In light of existing RAA requirements for Registrars’ retention and escrow of Privacy and Proxy Service Customer data, and in light of the discussions during the 24th January 2017 Privacy/Proxy Implementation Review Team meeting, the ICANN organization should implement data escrow and retention requirements for accredited Privacy and Proxy Service Providers as follows (choose one): 1. The data escrow and retention requirements for Registrars (with respect to Privacy/Proxy Customer data) should be superseded by new requirements for all accredited Privacy and Proxy Service Providers, so that Registrars would no longer be required to retain or escrow the underlying Customer data associated with Privacy and Proxy Service registrations offered or made available by the Registrar or its affiliates; or 2. ICANN should permit the Registrar and the accredited Privacy and Proxy Service Provider to choose whether the Registrar or the Provider will be responsible for escrow and retention of Customer data. In addition to this question, we will also discuss potential topics for our agenda at our half-day meeting at ICANN58. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl(a)icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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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Agenda and discussion question for 28 February Privacy/Proxy IRT meeting
by Amy Bivins Feb. 24, 2017

Feb. 24, 2017

Hello, All, I hope you are well! This is a reminder of the Privacy/Proxy Services Accreditation IRT call scheduled for 28 February 2017 at 15:00 UTC. I hope you can attend. Our agenda is fairly short, so the call will likely not last the full 90 minutes. Attached is a document that includes background material (text of relevant RAA provisions) and a discussion question for the call. I'm repeating the question here for convenience (if you wish to share your thoughts on this before Tuesday, please feel free to do so on the list): In light of existing RAA requirements for Registrars' retention and escrow of Privacy and Proxy Service Customer data, and in light of the discussions during the 24th January 2017 Privacy/Proxy Implementation Review Team meeting, the ICANN organization should implement data escrow and retention requirements for accredited Privacy and Proxy Service Providers as follows (choose one): 1. The data escrow and retention requirements for Registrars (with respect to Privacy/Proxy Customer data) should be superseded by new requirements for all accredited Privacy and Proxy Service Providers, so that Registrars would no longer be required to retain or escrow the underlying Customer data associated with Privacy and Proxy Service registrations offered or made available by the Registrar or its affiliates; or 2. ICANN should permit the Registrar and the accredited Privacy and Proxy Service Provider to choose whether the Registrar or the Provider will be responsible for escrow and retention of Customer data. In addition to this question, we will also discuss potential topics for our agenda at our half-day meeting at ICANN58. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Cancelled: Privacy/Proxy IRT meeting scheduled 21 Feb 2017
by Amy Bivins Feb. 16, 2017

Feb. 16, 2017

Hello, All, I hope you are well. Next week's Privacy/Proxy Implementation Review Team meeting (scheduled for 21 February 2017 at 15:00 UTC) has been canceled, because new materials are not ready to distribute to the IRT for discussion. For those of you who could not attend the IRT meeting on 2/14, I encourage you to listen to the recording, which is available on the wiki page, https://community.icann.org/display/IRT/14+February+2017. If anyone has further input on the RDDS labeling proposal that was distributed last week and discussed on Tuesday, please send it to the list this week. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Privacy/Proxy RDDS labeling document attached for 14 Feb IRT call
by Amy Bivins Feb. 13, 2017

Feb. 13, 2017

Hello, All, Attached is an initial discussion proposal for Tuesday's IRT call, exploring how we could potentially implement the Final Report's recommendation that, "To the extent that this is feasible, domain name registrations involving P/P service providers should be clearly labelled as such in WHOIS." (See Final Report, p. 9) To summarize, we have explored several possible alternatives for implementing this recommendation. The attached proposes to add four new fields, but also identifies the other possible alternatives that were considered. We are seeking your feedback on any and all elements of this proposal, including (1) the specific fields to be added; (2) the location(s) of the new fields; and (3) ensuring that this can be implemented from an operational perspective (particularly if/when a provider is not affiliated with the registrar). Once we have discussed the new fields and the preferred locations for these fields, we will ensure the final product is consistent with the new CL&D requirements. On Tuesday, I'll run through the proposal briefly and also note the other alternatives that were considered but not included here. The rest of the call will be dedicated to your discussion and feedback on this. Please share any preliminary feedback on the list and I look forward to talking with you on Tuesday. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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FW: IRT Responses to Privacy/Proxy Operational Questions
by Amy Bivins Feb. 9, 2017

Feb. 9, 2017

Hi, All, I apologize for the repeat message to some of you, I sent to the incorrect list. Best, Amy From: Amy Bivins Sent: Thursday, February 09, 2017 9:26 AM To: gnso-ppsai-pdp-wg(a)icann.org Subject: IRT Responses to Privacy/Proxy Operational Questions Hello, All, Thanks so much to those of you who completed the operational questions survey. The attached file contains a complete list of questions and the answers we received. I plan to distribute a labeling requirements proposal for us to discuss on Tuesday's call no later than tomorrow. Best, Amy Amy E. Bivins Registrar Policy Services 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 Requested by 8 Feb] PP IRT Operational Questions + New Materials for Review
by Amy Bivins Feb. 7, 2017

Feb. 7, 2017

Hello, All, I have attached updated questions related to the draft Policy sections 2, 5 and 6 for discussion on our 7 February call (attached in the table format recommended yesterday, but saved as a PDF). Please note that this document lacks the requested "staff recommendation" column-this will be added in future weeks). In addition, please complete this questionnaire no later than your end of day 8 February 2017, https://goo.gl/forms/CQLDwmbqYmOQuru63. The questionnaire includes some initial operational questions related to the implementation of this program. Please feel free to submit comments, questions and feedback on these to the list-you don't need to wait for our next call to share your feedback. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Slides/Questions for tomorrow's IRT call
by Amy Bivins Jan. 31, 2017

Jan. 31, 2017

Hello, All, In advance of tomorrow's IRT call (at 15:00 UTC), I am attaching the slide deck, which includes specific questions that I'll be asking you about tomorrow. If you have any feedback on these before the call, please feel free to share it on the list. These questions are also in the comments bubbles on the relevant Policy section drafts, but are easier to read in the slides. I look forward to speaking with you tomorrow! Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Re: [Gdd-gnso-ppsai-impl] Slides/Questions for tomorrow's IRT call
by Sara Bockey Jan. 31, 2017

Jan. 31, 2017

Agree that this would be very helpful! Sara From: <gdd-gnso-ppsai-impl-bounces(a)icann.org> on behalf of "Metalitz, Steven" <met(a)msk.com> Reply-To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Date: Tuesday, January 31, 2017 at 9:53 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Slides/Questions for tomorrow's IRT call Hi Amy and colleagues, Thanks for soliciting process and presentation suggestions to try to minimize the confusion expressed by several of us on today’s call. One problem is that the questions are coming to the IRT through multiple channels – the “comment bubbles” on the word doc, via free-standing e-mail from staff, in the slides, and then formulated orally by staff on the call. These questions are not always the same. Could staff prepare a unified chart that, for each issue, contains (1) the relevant PDP report text; (2) the specific issue identified as a concern for implementation; (3) the specific question you would like IRT feedback on (in most cases, this could be in yes-or-no format, though in some cases additional options might be needed); and (4) (where feasible) a recommendation from the staff on how to handle? If that could be distributed well in advance of the weekly call, we might be able to dispose of some questions on the list, and in any case this might facilitate the discussion and ultimate recommendation on the call. Steve Metalitz [mage001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Monday, January 30, 2017 1:14 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Slides/Questions for tomorrow's IRT call Hello, All, In advance of tomorrow’s IRT call (at 15:00 UTC), I am attaching the slide deck, which includes specific questions that I’ll be asking you about tomorrow. If you have any feedback on these before the call, please feel free to share it on the list. These questions are also in the comments bubbles on the relevant Policy section drafts, but are easier to read in the slides. I look forward to speaking with you tomorrow! Best, Amy Amy E. Bivins Registrar Policy Services 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] Slides/Questions for tomorrow's IRT call
by Jennifer Gore Jan. 30, 2017

Jan. 30, 2017

Amy, Thanks for sharing the slide deck. The only minor suggestion is as follows: · Slide 3: ICANN58 IRT meeting scheduled for Saturday, 11 March, 1:45-6:30 – indicate the time into UTC. 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, January 30, 2017 at 1:13 PM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Slides/Questions for tomorrow's IRT call Hello, All, In advance of tomorrow’s IRT call (at 15:00 UTC), I am attaching the slide deck, which includes specific questions that I’ll be asking you about tomorrow. If you have any feedback on these before the call, please feel free to share it on the list. These questions are also in the comments bubbles on the relevant Policy section drafts, but are easier to read in the slides. I look forward to speaking with you tomorrow! Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Updated PP Policy Section 1
by gtheo Jan. 30, 2017

Jan. 30, 2017

Hi Amy, AB24 has not been updated yet, I do recall on the list that Roger Carney made some good suggestions here and got support on the list. Or is this still pending discussion. AB10, I think Darcy is right here on the intent. Thanks, Theo

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Updated draft Section 2, questions to continue reviewing on 31 January IRT call
by Amy Bivins Jan. 27, 2017

Jan. 27, 2017

Hi, All, Per the additional comments on the list, I've updated this Section 2 document slightly, and I've incorporated additional questions into this document to continue our discussion next week. On our upcoming call on Tuesday, 31 January, at 15:00 UTC, discussion on this Section 2 document will pick up at Section II.E, Terms and Conditions. Update on ICANN58 Meeting It has been decided that we will have a half-day IRT meeting at ICANN58, on Saturday, 11 March, in the afternoon (I have requested space for the three afternoon time slots-so we will have space from 1:45-6:30). I apologize for the late notice on the approved day. As this is an official meeting day, I realize there may be conflicts, but I hope that you can attend so that we can make the most of this time. If you have questions, please let me know. Initial Discussion Question Before we dive back into Section 2 on Tuesday, I'm going to ask for your feedback about one set of recommendations. The recommendations are as follows: (see P13, item 15) A uniform set of minimum mandatory criteria that must be followed for the purpose of reporting abuse and submitting requests (including requests for the Disclosure of customer information) should be developed. Forms that may be required by individual P/P service providers for this purpose should also include space for free form text. P/P service providers should also have the ability to "categorize" reports received, in order to facilitate responsiveness. P/P service providers must also state the applicable jurisdiction in which disputes (including any arising under the Illustrative Disclosure Framework in Annex B) should be resolved on any forms used for reporting and requesting purposes. (see p.64) The WG also recommends that the use of standard forms and other mechanisms that would facilitate the prompt and accurate identification of a Relay request be explored during implementation (e.g. drop-down menus in a provider's web-based forms or fields that would require the filling in of a Requester's contact details, specifying the type of request or other basic information). These recommendations seem to indicate that this implementation should deliver (a) minimum mandatory criteria and required processes for abuse reports, information requests, and relay requests, by (b) developing a list of standard categories for requests to PP service providers and (c) identifying any specific requirements for the individual types of requests or reports. Can the IRT provide any further guidance regarding what the PDP WG intended here or confirm whether this understanding is correct? Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Specifics related to PP IRT discussion on data escrow/retention on 1/24 IRT call
by Amy Bivins Jan. 25, 2017

Jan. 25, 2017

Hello, All, I reviewed yesterday's call recording to compile a full summary of the input we received from you related to the questions related to possible requirements on data escrow and retention. At the outset of our discussion on data escrow and data retention (beginning around 25:30 on the call), there was some hesitation by some in the room to discussing potential requirements for PP service providers. However, as we got further into the discussion, there seemed to be support for exploring proposals on these topics, but only to ensure that the requirements are the same for PP service providers regardless of whether or not the provider is Affiliated with a registrar (and ensuring no duplicate requirements for registrars). There are documented PDP WG discussions on data escrow. I have not located any WG discussion specifically on data retention. However, there are existing RAA requirements for retention of PP customer contact information. This, coupled with PDP WG discussions about ensuring that customers are protected to the extent possible if an accredited PP service is terminated or goes out of business, seems to imply that such a requirement-retaining a limited set of Customer information (name, email, address, telephone number) to ensure that these Customers can be contacted in this situation-may fall within the intent of the PDP WG recommendations. This interpretation seemed to be supported by many on the call yesterday, including Theo, Chris, Steve and Susan. As a result, based on the discussion yesterday, we will proceed with drafting proposals on these topics to be discussed with the IRT, unless there is a continuing question regarding whether this was within the intent of the PDP WG. If anyone on the IRT wishes to comment on this, specifically on whether you believe this is within or beyond the intent of the PDP WG, please do so by replying to this thread. The current RAA requirements are noted below. Specification on Privacy and Proxy Registrations (expires 1 January 2018): "2.5 Escrow of P/P Customer Information. Registrar shall include P/P Customer contact information in its Registration Data Escrow deposits required by Section 3.6 of the Agreement. P/P Customer Information escrowed pursuant to this Section 2.5 of this Specification may only be accessed by ICANN in the event of the termination of the Agreement or in the event Registrar ceases business operations." Note-this requirement to escrow PP customer contact information will expire with the interim specification RAA 3.6 Data Escrow. During the Term of this Agreement, on a schedule, under the terms, and in the format specified by ICANN, Registrar shall submit an electronic copy of the data described in Subsections 3.4.1.2 through 3.4.1.5 to ICANN or, at Registrar's election and at its expense, to a reputable escrow agent mutually approved by Registrar and ICANN, such approval also not to be unreasonably withheld by either party. The data shall be held under an agreement among Registrar, ICANN, and the escrow agent (if any) providing that (1) the data shall be received and held in escrow, with no use other than verification that the deposited data is complete, consistent, and in proper format, until released to ICANN; (2) the data shall be released from escrow upon expiration without renewal or termination of this Agreement; and (3) ICANN's rights under the escrow agreement shall be assigned with any assignment of this Agreement. The escrow shall provide that in the event the escrow is released under this Subsection, ICANN (or its assignee) shall have a non-exclusive, irrevocable, royalty-free license to exercise (only for transitional purposes) or have exercised all rights necessary to provide Registrar Services. (NOTE-this is a data retention requirement-the same data that is required to be retained is required to be escrowed) 3.4.1.5 the name, postal address, e-mail address, and voice telephone number provided by the customer of any privacy service or licensee of any proxy registration service, in each case, offered or made available by Registrar or its Affiliates in connection with each registration. Effective on the date that ICANN fully implements a Proxy Accreditation Program established in accordance with Section 3.14, the obligations under this Section 3.4.1.5 will cease to apply as to any specific category of data (such as postal address) that is expressly required to be retained by another party in accordance with such Proxy Accreditation Program (emphasis added). Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Re: [Gdd-gnso-ppsai-impl] Updated draft PP Policy Section 2, updates from today's Privacy/Proxy IRT call
by Darcy Southwell Jan. 25, 2017

Jan. 25, 2017

Hi, Amy. Thanks for the quick turnaround on this draft. Just to clarify – we didn’t discuss that all uses of “should” would be changed to “shall” in a blanket fashion. Just the paragraphs we discussed/voted on. Were additional changes made that we didn’t discuss? As we discussed today regarding II(C), in order to avoid duplication of messaging to registrants, this paragraph should also include an exception, similar in nature to II(D)(ii), that a P/P services does not have to send this if the registrar it is affiliated with has also done this. I know we plan to come back to Section E (Privacy and Proxy Terms of Service) later on, but I wanted to point out something about the II(E)(vii) – per the footnote, the PDP did not indicate that the terms of service had to include pricing, but that the pricing had to be displayed to customers. This is also similar to Consensus Policies registrars must follow. I don’t believe the intent was for the pricing to be a part of the terms of service. We didn’t discuss AB25 today regarding II(I) but I wanted to add a comment for discussion. Based on the footnote and my memory, I don’t think this is for reports of all abuse “involving Registered Names that are registered through the Privacy and/or Proxy provider.” Domains are registered with the registrar or registrar’s reseller and the registrar is responsible for investigating abuse. I think the PDP’s intent was for P/P providers to maintain a contact for abuse relating to the P/P services only. Thanks, Darcy 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> Date: Tuesday, January 24, 2017 at 9:45 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Updated draft PP Policy Section 2, updates from today's Privacy/Proxy IRT call Hello, All, Thanks so much for your active participation on the Privacy/Proxy IRT call today—we had a very productive meeting. I’m attaching an updated version of Section 2 of the draft Policy document, which reflects our discussion on the call today. To summarize, instances of “SHOULD” in the document have been changed to “SHALL” pursuant to discussion on the call about what the PDP WG intended—that these would be requirements, not best practices. Nearly everyone who participated in the “green check/red x” ask seemed to agree with this, with the exception of Volker. Volker, if you would like to share any additional thoughts or reasoning surrounding the WG’s intent here and if anyone else feels strongly about this, please comment on the list. We want a full record and to ensure that we have interpreted the WG’s intent accurately, so we encourage everyone to please speak up (on this and always!). I’ve also made some updates to the “data reminders” and “terms of service” section. And we will pick up on the ToS section next week. Materials from the call will be posted on the wiki shortly. If anyone has questions or comments in the interim please reply to the list, and I will share any new materials with you as they are available. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.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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Updated draft PP Policy Section 2, updates from today's Privacy/Proxy IRT call
by Amy Bivins Jan. 24, 2017

Jan. 24, 2017

Hello, All, Thanks so much for your active participation on the Privacy/Proxy IRT call today-we had a very productive meeting. I'm attaching an updated version of Section 2 of the draft Policy document, which reflects our discussion on the call today. To summarize, instances of "SHOULD" in the document have been changed to "SHALL" pursuant to discussion on the call about what the PDP WG intended-that these would be requirements, not best practices. Nearly everyone who participated in the "green check/red x" ask seemed to agree with this, with the exception of Volker. Volker, if you would like to share any additional thoughts or reasoning surrounding the WG's intent here and if anyone else feels strongly about this, please comment on the list. We want a full record and to ensure that we have interpreted the WG's intent accurately, so we encourage everyone to please speak up (on this and always!). I've also made some updates to the "data reminders" and "terms of service" section. And we will pick up on the ToS section next week. Materials from the call will be posted on the wiki shortly. If anyone has questions or comments in the interim please reply to the list, and I will share any new materials with you as they are available. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Materials and questions for 24 January PP IRT Call
by Amy Bivins Jan. 24, 2017

Jan. 24, 2017

Dear Colleagues, Attached are documents for discussion on Tuesday's (24 January, 15:00 UTC) Privacy and Proxy Service Provider Accreditation Program IRT call: draft Policy sections 2, 5, and 6. We will review as much of these documents as we can Tuesday, and continue with them next week, if needed. The poll results show a clear preference for weekly meetings, so we will be moving to that schedule-thank you for your participation in the poll! A meeting reminder will be distributed on Monday. I want to flag some of the questions we have for you on Section 2, as noted in more detail in the attached: 1. The Final Report in some cases uses the word "SHOULD." ICANN org requests the IRT's feedback on the PDP WG's intent in using the word (as SHOULD is defined here: http://www.ietf.org/rfc/rfc2119.txt) and whether "SHALL" was intended in any of these instances. 2. With respect to data reminders, did the PDP WG intend for these reminders to reference (a) any Customer information that appears in WHOIS, (b) the underlying Customer data, or (c) both? 3. With respect to data validation and verification, did the PDP WG intend for the requirement to apply to (a) any Customer data, as relevant, in WHOIS; (b) underlying Customer data, as relevant, or (c) both? (Additional questions in document) 4. Did the PDP WG intend for ICANN org to implement new requirements for Privacy and Proxy Service providers to escrow and retain data, distinct from the existing requirements in the RAA? 5. Did the PDP WG intend for this implementation to create minimum, mandatory criteria for all requests to Privacy and Proxy Service providers (See draft Section 2.J)? We will also seek your feedback on the level of detail that is being proposed for the Policy versus the contract. If you have any questions or want to begin to discussing these issues on-list before the call, please feel free to do so. I look forward to speaking with you on Tuesday. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Jan. 24 PPSAI IRT call? WAS RE: Cancelation of 17 January IRT meeting; Please complete IRT poll re: schedule
by Metalitz, Steven Jan. 21, 2017

Jan. 21, 2017

Amy, I have seen no notice for the Jan. 24 call, nor any materials for review prior to the call. Is the meeting still on, does it start at 1500 UTC, and when will drafts for review be distributed? Thanks. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Friday, January 13, 2017 12:08 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Cancelation of 17 January IRT meeting; Please complete IRT poll re: schedule Dear Colleagues, Upon further consideration, we have decided to cancel the Privacy and Proxy Service Provider Accreditation Program IRT meeting that is scheduled for this upcoming Tuesday, the 17th. Given that Monday is a U.S. holiday (I had forgotten about this during our IRT call), there is not adequate time to distribute the necessary documents for review before the call. I sincerely apologize for any inconvenience. Looking ahead, in an effort to ensure we proceed conservatively and transparently, and that we clearly understand and document all IRT members' intent surrounding our timeline and meeting schedule, we request that you complete the following poll no later than Wednesday, 18 January: https://www.surveymonkey.com/r/FTW57SC On our call on Tuesday the 10th, I asked two discrete questions regarding our timeline and call schedule, and the responses we received in the Adobe room were as follows: Question 1: Should this IRT adopt the 12-month timeline circulated to the IRT in December (question asked at approximately 8:23 on recording)? Attendees in room (including some staff): 30 Yes: (2)-Alex Deacon and Steve Metalitz (Steve elaborated on audio that the IRT should proceed to the substance of this implementation and hold weekly meetings, and see how quickly we can proceed rather than explicitly adopting the 12-month timeline) No: (8) Leana Vitruk (on the phone); Alejandro Hernandez, Carolyn Mitchell, Darcy Southwell, Eric Rokobauer, Greg DiBiase, Janelle McAlister, Lisa Villeneuve Question 2: Is anyone opposed to moving to weekly meetings (in response to discussion at end of call regarding the need for timely scheduling and adequate notice of meetings, at approximately 53:00)? Attendees in room (including some staff): 33 Yes (meaning, IRT should move to weekly meetings): (8) Alejandro Hernandez, Alex Deacon, Eric Rokobauer, Leana Vitruk, Lisa Villeneuve, Roger Carney, Steve Metalitz, Vlad Dinculescu No (meaning, opposed to moving to weekly schedule): (2): Carolyn Mitchell, Greg DiBiase Based on the more "yes's" than "no's" to Question 2, and the discussion on the audio, which seemed to support moving to weekly meetings, I committed to schedule weekly meetings. However, many IRT members did not answer the question (and some were not on the call). This is why we are asking you to complete the above-linked poll, to ensure we clearly understand and correctly interpret all IRT members' views on this topic. Our next meeting is scheduled for 24 January 2017. If your survey responses reflect the apparent intent in the room on the 10 January call, we will proceed to adopt the proposed weekly meeting schedule as of our 24 January meeting. Best, Amy Amy E. Bivins Registrar Policy Services 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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Action Required by 20 Jan: IRT Poll Re: Schedule
by Amy Bivins Jan. 19, 2017

Jan. 19, 2017

Dear Colleagues, This is a reminder that we have asked you to participate in a poll regarding a proposed change to the IRT meeting schedule (to meet weekly rather than biweekly), https://www.surveymonkey.com/r/FTW57SC. As of today, we only have 9 responses. Please respond to this very short three-question poll no later than tomorrow, 20 January. We need feedback from as many of you as possible (including the full spectrum of stakeholder groups and constituencies represented on the IRT). These current results represent the views of only a small fraction of the IRT. We need responses from all of you so that we can make a fully-informed decision regarding the IRT meeting schedule. Thank you for your assistance on this. I will be distributing the documents for discussion at our 24 January meeting to you on Monday. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org From: gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Friday, January 13, 2017 12:08 PM To: gdd-gnso-ppsai-impl(a)icann.org Subject: [Gdd-gnso-ppsai-impl] Cancelation of 17 January IRT meeting; Please complete IRT poll re: schedule Dear Colleagues, Upon further consideration, we have decided to cancel the Privacy and Proxy Service Provider Accreditation Program IRT meeting that is scheduled for this upcoming Tuesday, the 17th. Given that Monday is a U.S. holiday (I had forgotten about this during our IRT call), there is not adequate time to distribute the necessary documents for review before the call. I sincerely apologize for any inconvenience. Looking ahead, in an effort to ensure we proceed conservatively and transparently, and that we clearly understand and document all IRT members' intent surrounding our timeline and meeting schedule, we request that you complete the following poll no later than Wednesday, 18 January: https://www.surveymonkey.com/r/FTW57SC On our call on Tuesday the 10th, I asked two discrete questions regarding our timeline and call schedule, and the responses we received in the Adobe room were as follows: Question 1: Should this IRT adopt the 12-month timeline circulated to the IRT in December (question asked at approximately 8:23 on recording)? Attendees in room (including some staff): 30 Yes: (2)-Alex Deacon and Steve Metalitz (Steve elaborated on audio that the IRT should proceed to the substance of this implementation and hold weekly meetings, and see how quickly we can proceed rather than explicitly adopting the 12-month timeline) No: (8) Leana Vitruk (on the phone); Alejandro Hernandez, Carolyn Mitchell, Darcy Southwell, Eric Rokobauer, Greg DiBiase, Janelle McAlister, Lisa Villeneuve Question 2: Is anyone opposed to moving to weekly meetings (in response to discussion at end of call regarding the need for timely scheduling and adequate notice of meetings, at approximately 53:00)? Attendees in room (including some staff): 33 Yes (meaning, IRT should move to weekly meetings): (8) Alejandro Hernandez, Alex Deacon, Eric Rokobauer, Leana Vitruk, Lisa Villeneuve, Roger Carney, Steve Metalitz, Vlad Dinculescu No (meaning, opposed to moving to weekly schedule): (2): Carolyn Mitchell, Greg DiBiase Based on the more "yes's" than "no's" to Question 2, and the discussion on the audio, which seemed to support moving to weekly meetings, I committed to schedule weekly meetings. However, many IRT members did not answer the question (and some were not on the call). This is why we are asking you to complete the above-linked poll, to ensure we clearly understand and correctly interpret all IRT members' views on this topic. Our next meeting is scheduled for 24 January 2017. If your survey responses reflect the apparent intent in the room on the 10 January call, we will proceed to adopt the proposed weekly meeting schedule as of our 24 January meeting. Best, Amy Amy E. Bivins Registrar Policy Services 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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Cancelation of 17 January IRT meeting; Please complete IRT poll re: schedule
by Amy Bivins Jan. 13, 2017

Jan. 13, 2017

Dear Colleagues, Upon further consideration, we have decided to cancel the Privacy and Proxy Service Provider Accreditation Program IRT meeting that is scheduled for this upcoming Tuesday, the 17th. Given that Monday is a U.S. holiday (I had forgotten about this during our IRT call), there is not adequate time to distribute the necessary documents for review before the call. I sincerely apologize for any inconvenience. Looking ahead, in an effort to ensure we proceed conservatively and transparently, and that we clearly understand and document all IRT members' intent surrounding our timeline and meeting schedule, we request that you complete the following poll no later than Wednesday, 18 January: https://www.surveymonkey.com/r/FTW57SC On our call on Tuesday the 10th, I asked two discrete questions regarding our timeline and call schedule, and the responses we received in the Adobe room were as follows: Question 1: Should this IRT adopt the 12-month timeline circulated to the IRT in December (question asked at approximately 8:23 on recording)? Attendees in room (including some staff): 30 Yes: (2)-Alex Deacon and Steve Metalitz (Steve elaborated on audio that the IRT should proceed to the substance of this implementation and hold weekly meetings, and see how quickly we can proceed rather than explicitly adopting the 12-month timeline) No: (8) Leana Vitruk (on the phone); Alejandro Hernandez, Carolyn Mitchell, Darcy Southwell, Eric Rokobauer, Greg DiBiase, Janelle McAlister, Lisa Villeneuve Question 2: Is anyone opposed to moving to weekly meetings (in response to discussion at end of call regarding the need for timely scheduling and adequate notice of meetings, at approximately 53:00)? Attendees in room (including some staff): 33 Yes (meaning, IRT should move to weekly meetings): (8) Alejandro Hernandez, Alex Deacon, Eric Rokobauer, Leana Vitruk, Lisa Villeneuve, Roger Carney, Steve Metalitz, Vlad Dinculescu No (meaning, opposed to moving to weekly schedule): (2): Carolyn Mitchell, Greg DiBiase Based on the more "yes's" than "no's" to Question 2, and the discussion on the audio, which seemed to support moving to weekly meetings, I committed to schedule weekly meetings. However, many IRT members did not answer the question (and some were not on the call). This is why we are asking you to complete the above-linked poll, to ensure we clearly understand and correctly interpret all IRT members' views on this topic. Our next meeting is scheduled for 24 January 2017. If your survey responses reflect the apparent intent in the room on the 10 January call, we will proceed to adopt the proposed weekly meeting schedule as of our 24 January meeting. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Updated PP Policy Section 1, update from 1/10 IRT call
by Amy Bivins Jan. 12, 2017

Jan. 12, 2017

Hello, All, Thanks so much for your active participation on our IRT call today-I think we can all agree that we made substantial progress! I am attaching an updated draft of Section 1 of the policy, incorporating edits after our call today and some new comments that were received after the Friday deadline. If you have any additional comments on this, please send them to the list this week while the discussion is still fresh on everyone's minds. I cleaned up this document by deleting the comments and making a couple of edits that I believe were addressed on the call (but if you disagree with any changes that were made please let me know). For those who were not on the call, please review the call materials and listen to the recording this week. We had a very robust discussion. There was general support on the call to begin meeting weekly, so we will update our meeting schedule to start that next week. If anyone who was not on the call wishes to weigh in on this, please reply to the list. As you will hear on the recording, there was general agreement on the call to work to expedite our pace, to the extent that we can without sacrificing the quality of our output. So the first step on that is to start meeting weekly. I will distribute materials for next week's call no later than Monday, and the materials from today's call should be up on the wiki shortly. If you have questions or comments please don't hesitate to contact me directly or reply to the list (preferred, so that everyone can see). Also, a reminder that any feedback on the LEA framework principles document (distributed to the LEA issues subteam and available on the wiki) should be sent to the list no later than Friday, 13 January. And I will be following up with the registrars who spoke up on the call about starting subteam work related to developing a proposed process that we will fit in to Section 1 C (when a registrar/reseller becomes aware of registrations involving an unaccredited privacy or proxy service). Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Agenda, materials for 10 January IRT call
by Amy Bivins Jan. 10, 2017

Jan. 10, 2017

Hi All, Our next Privacy and Proxy Service Provider Accreditation Program IRT meeting is scheduled for 10 January 2017, 15:00 UTC, for 90 minutes. You should have received a calendar invitation and login information separately (if not, or you need this resent, please let me know). Our agenda is as follows: >Recent developments >Overview and IRT feedback on illustrative 12-month project timeline >Overview and IRT feedback on draft v2, Privacy and Proxy Service Provider Accreditation Policy, Section 1 (attached document updated with IRT comments received and additional ICANN comments attached) >Next steps This morning, I distributed a document to the LEA issues subteam for feedback (attached). If you are not part of the subteam but would like to provide feedback, please send any input no later than 13 January. I look forward to speaking with you tomorrow. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Re: [Gdd-gnso-ppsai-impl] Agenda, materials for 10 January IRT call
by Michele Neylon - Blacknight Jan. 9, 2017

Jan. 9, 2017

I am probably going to be stuck on a plane somewhere at that time, so please accept my apologies Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains http://www.blacknight.host/ http://blacknight.blog/ http://ceo.hosting/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 ------------------------------- 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: Monday 9 January 2017 at 09:41 To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Agenda, materials for 10 January IRT call Hi All, Our next Privacy and Proxy Service Provider Accreditation Program IRT meeting is scheduled for 10 January 2017, 15:00 UTC, for 90 minutes. You should have received a calendar invitation and login information separately (if not, or you need this resent, please let me know). Our agenda is as follows: >Recent developments >Overview and IRT feedback on illustrative 12-month project timeline >Overview and IRT feedback on draft v2, Privacy and Proxy Service Provider Accreditation Policy, Section 1 (attached document updated with IRT comments received and additional ICANN comments attached) >Next steps This morning, I distributed a document to the LEA issues subteam for feedback (attached). If you are not part of the subteam but would like to provide feedback, please send any input no later than 13 January. I look forward to speaking with you tomorrow. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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[Response Requested by 6 January] Draft Section I PP Policy, Illustrative 12-month timeline
by Amy Bivins Jan. 6, 2017

Jan. 6, 2017

Hello, All, I have a few developments to share with you. Items 3 and 4 require action from you, so please review this message carefully. First, ICANN will be formally announcing to accredited registrars today that the expiration date of the 2013 RAA Specification on Privacy and Proxy Registrations is extended to 1 January 2018. Second, the new LEA subgroup page is up the wiki, https://community.icann.org/display/IRT/Subgroup%3A+Law+Enforcement+Authorit y+Issues. The subgroup likely won't meet until shortly before ICANN58, but I am glad that so many of you have signed up and that we have the subgroup ready when there is a proposal ready to discuss. I'll continue to share all information I have about this effort with you (this effort should be officially kicked off with the PSWG in early January). Third, a first draft of Section 1 of the Privacy and Proxy Service Provider Accreditation Provider is attached and ready for your review. We will be discussing this on our 10 January call. Please provide your initial feedback to the list no later than your EOD 6 January, so that we can plan for how to allocate time for this topic on the next call. Fourth, pursuant to a request on the 13 December 2016 call, ICANN has prepared an illustrative timeline showing our best estimate for how we could attempt to compress the existing project plan into a one-year timeline to coincide with the new 1 January 2018 expiration date of the interim 2013 RAA Specification. Please note: * This is ICANN's best estimate only. If the IRT wants to pursue this compressed timeline, this plan could shift and change along the way due to a variety of factors and dependencies, many beyond ICANN's (and the IRT's) control (for example, an additional deliverable on Transfer Policy requirements might need to be added to the project plan). * The distribution of this illustrative timeline is not an ICANN endorsement of this timeline. There could be significant impacts to the initial application process and account management infrastructure, at a minimum, to rolling out this program at this pace-impacts that might be seen as detrimental by some within the community. For example, it is unlikely that ICANN will have a portal/system in place to accept applications and for accredited services to manage their accounts by 1 January 2018, even if the final implementation can be announced as soon as October 2017. * Dates noted in the timeline should not be interpreted as a commitment by ICANN, as meeting each milestone will depend on a multitude of factors. * Moving along at this pace would require weekly meetings, at a minimum. IRT discussion on topics that must be decided upon each week would either (a) need to be time-limited, by some process (suggested time allotments in the illustrative example are for discussion purposes only), or (b) the IRT would likely need to have longer or multiple meetings during at least some weeks to stay on schedule and resolve the relevant topic(s). * Meeting this illustrative timeline would significantly impact the burdens placed on staff and IRT volunteers. This could have a significant impact on the costs required to implement this program. * We want to stress the importance of ensuring that the final program implementation is sound and delivers what the PDP WG intended. This cannot be sacrificed for speed's sake (though staff will do everything we can to be efficient managers of this process). * ICANN will require at least 6+ months to become operationally ready to process applications for accreditation after all program requirements are finalized. With those cautions firmly in mind, ICANN commits to use all reasonable efforts to adhere closely to this proposed timeline if the IRT wants to pursue this path. Please provide your feedback on this timeline no later than 6 January 2017. If the IRT would like to explore some compromise between the originally proposed timeline and this 12-month timeline, ICANN is also open to that (this exercise identified some areas where this timeline might be compressed with lesser impacts on overall burdens than the 12-month timeline attached). Fifth, I have consulted internally regarding the appropriate day(s) for scheduling face-to-face meetings before ICANN58 (which was the most popular option in the Doodle poll, by one vote). The schedule is not set yet, so I apologize that the poll was premature. I will let you know as soon as I know what the approved date(s) for a day-long meeting prior to ICANN58 would be. Finally, this is a reminder that ICANN offices are closed 24 December until 2 January. I hope that you all have a happy and healthy holiday season (for those who celebrate) and I look forward to working with you all in the new year. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Board approves GAC scorecard, including provision on Privacy/Proxy IRT
by Amy Bivins Dec. 20, 2016

Dec. 20, 2016

Hi All, On Tuesday, the Board approved the GAC scorecard, "GAC Advice <https://www.icann.org/en/system/files/files/resolutions-helsinki56-gac-advi ce-scorecard-13dec16-en.pdf> -Helsinki Communique Actions and Updates," which includes information relevant to the Privacy and Proxy Service Provider Accreditation Program IRT (see p. 3-4). The Board resolution "encourages the Implementation Review Team to continue to work with the Public Safety Working Group to address the concerns expressed by the GAC regarding accreditation of privacy/proxy service providers." To that end, staff is working to set up a meeting with interested members of the PSWG in early January to discuss (a) the process for developing a proposed law enforcement disclosure framework for discussion with the IRT, (b) the scope and limits of the Final Policy Recommendations with respect to this framework and (c) the time-sensitive nature of this process. If you want participate in a subgroup on this topic, please let me know. It may be a couple of months before the subgroup meets (to give the PSWG time to develop a strawman proposal to be vetted through the subgroup before presentation to the full IRT). All of the work on this topic and details of the process will be posted on the public wiki. Also, as an update-we are working on an illustrative timeline that will show how we might compress this project timeline to match the new RAA interim specification expiration date (1 January 2018). This is being reviewed internally and I expect to be able to share it with you next week. Also, I'm doing everything I can to have draft Policy documents for our 10 January meeting ready and approved for distribution to you by the end of next week. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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materials, Doodle poll referenced on Privacy/Proxy IRT call today
by Amy Bivins Dec. 14, 2016

Dec. 14, 2016

Hi, All, Thanks so much for your participation on the Privacy and Proxy Service Provider Accreditation Program IRT call earlier today. If you were unable to attend, materials and call information will be posted on the wiki shortly. As mentioned on the call today, we are considering the possibility of having an IRT face-to-face meeting this Spring, either before the ICANN58 meeting in Copenhagen or at the GDD Summit (in Madrid, in May). To that end, please participate in this Doodle poll no later than Friday, 16 December, http://doodle.com/poll/4v48dy362nef2n83 . As promised on the call today, I am attaching a more detailed project plan-outlining proposed topics for each scheduled IRT meeting. Please submit your feedback on this no later than 23 December. Your feedback on areas where we might be able to shorten this timeline would be especially helpful. As discussed this morning, we are working on an illustrative timeline of how we might reduce this project to a one-year time frame. We have a lot to cover, but we will develop the best proposal we can so that you can see how we might be able to compress this timeframe. Lastly, I want to re-emphasize that we (as staff who are working on this implementation project) are always open to hearing your suggestions, comments and concerns surrounding this project. If you, as an individual IRT member, or any of your larger constituencies, would like to schedule a meeting to discuss this project or specific topics therein, please don't hesitate to ask-we welcome all the input we can receive on this in addition to your participation in the IRT meetings. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Agenda for 13 December Privacy/Proxy IRT call
by Amy Bivins Dec. 13, 2016

Dec. 13, 2016

Hi All, Our agenda for tomorrow's Privacy and Proxy Service Provider Accreditation Program IRT meeting is available on the community wiki, https://community.icann.org/display/IRT/13+December+2016, and is as follows: >IRT feedback on draft v1 Policy Outline >Brief presentation on ICANN operational planning >Review of updated timeline >Next steps We will be in this Adobe Connect room: https://participate.icann.org/ppirt Dial-in information is attached to the calendar invitation that you should have received separately (a reminder went out this morning). If you have questions or comments beforehand, please don't hesitate to contact me. And if anyone did not receive the calendar invitation, please let me know (we have a separate distribution list for invitations which has caused a few IRT members to not properly receive invitations). Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Re: [Gdd-gnso-ppsai-impl] Reminder: Please Submit Feedback on Draft PP Policy Outline
by Darcy Southwell Dec. 12, 2016

Dec. 12, 2016

Thanks, Amy. This looks like a good start. I am a bit confused by the first sentence in §II. “As a condition of obtaining and maintaining ICANN accreditation, privacy and proxy service providers must enter and maintain in effect accreditation agreements with ICANN.” Does the first mention of “accreditation” in that sentence refer to something other than privacy/proxy accreditation? It’s a bit confusing the way it reads. Thanks, Darcy 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> Date: Thursday, December 8, 2016 at 8:46 AM To: "gdd-gnso-ppsai-impl(a)icann.org" <gdd-gnso-ppsai-impl(a)icann.org> Subject: [Gdd-gnso-ppsai-impl] Reminder: Please Submit Feedback on Draft PP Policy Outline Hi, All, This is a reminder that we are seeking your feedback on the draft Privacy and Proxy Service Provider Accreditation Policy outline. Please send your feedback to the list no later than Monday, 12 December so that we can discuss on our 13 December IRT call. The majority of the 13 December IRT call will be dedicated to your feedback on the outline. Thus, the length of the call will be largely dependent on how much feedback you would like to share. I’ll also share a slightly updated project timeline, taking into account our biweekly meeting schedule. I won’t have anything ready to report from the Board meeting yet, as it is now scheduled for the same day as our meeting. I look forward to speaking with you next week. In the interim, if you have questions or comments, please feel free to share on the list or to contact me directly. Best, Amy E. Bivins Registrar Policy Services 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 www.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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Reminder: Please Submit Feedback on Draft PP Policy Outline
by Amy Bivins Dec. 10, 2016

Dec. 10, 2016

Hi, All, This is a reminder that we are seeking your feedback on the draft Privacy and Proxy Service Provider Accreditation Policy outline. Please send your feedback to the list no later than Monday, 12 December so that we can discuss on our 13 December IRT call. The majority of the 13 December IRT call will be dedicated to your feedback on the outline. Thus, the length of the call will be largely dependent on how much feedback you would like to share. I'll also share a slightly updated project timeline, taking into account our biweekly meeting schedule. I won't have anything ready to report from the Board meeting yet, as it is now scheduled for the same day as our meeting. I look forward to speaking with you next week. In the interim, if you have questions or comments, please feel free to share on the list or to contact me directly. Best, Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Recording, Attendance & AC Chat for Privacy and Proxy Services Accreditation IRT Meeting on Tuesday, 29 November 2016 at 14:00 UTC
by Michelle DeSmyter Nov. 30, 2016

Nov. 30, 2016

Dear All, Please find the attendance of the call attached to this email and the AC recording below for the Privacy and Proxy Services Accreditation IRT Meeting held on Tuesday, 29 November 2016 at 14:00 UTC. Attendance of the calls is also posted on the agenda wiki page: https://community.icann.org/x/3I-DAw AC Recording: https://participate.icann.org/p67o5hqw02q/ ** Please let me know if your name has been left off the list ** Thank you. Kind regards, Michelle ------------------------------- Adobe Connect chat transcript for Tuesday, 29 November 2016 Michelle DeSmyter:Dear All, Welcome to the Privacy and Proxy Services Accreditation Program IRT Meeting on Tuesday, 29 November 2016 at 14:00 UTC. Michelle DeSmyter:Agenda page: https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_x_… Chris Pelling:Good afternoon all, could we make the chat window slightly taller please ? Chris Pelling:Many thanks, I have 2 lines now :) Tom Kinstler:Good Day to all Graeme Bunton:Morning all. Theo Geurts:hiyas Chris Pelling:Thius time is perfect for me Chris Pelling:I dont see a check mark - sorry Ashley Heineman:I support the time. I'm clearly an idiot.. as I don't see a green check mark. Chris Pelling:yes please :) Sara Bockey:I'm fine with pushing it forward an hour, but this time works for me as well Ashley Heineman:learn something new every day. Chris Pelling:aha found it thanks :) steve metalitz:I am also fine either way and this slot is awfully early for PST Tom Kinstler:Please can you send an email detailing the type of candidate you are looking for in order for us to forward to the right people. Graeme Bunton:My recollection is that the PDP struggled to identify any as well Tom Kinstler:Understood, thank you. Tom Kinstler:YES PLEASE! Greg DiBiase:yes please Carlton Samuels:Morning all Carlton Samuels:My apologies for the late join; connection issues Michele Neylon:Sorry - Can't speak not dialled in - am currently on hold with my bank Mary Wong:We also hope to get specific feedback from the PSWG and the GAC on a potential scope of Section IV Mary Wong:@Tom, wouldn't that come under Section III? Chris Pelling:Within UDRP, that already existts Mary Wong:I believe the existing IP Disclosure Framework allows for trademark holders to make requests, including if the domain is subject to a UDRP proceeding. Nick Shorey:Has the IRT leadership received any further indication from the Board on when further guidance re GAC advice is likely to be received? Nick Shorey:cool - i love short answers! Thanks! Mary Wong:@Nick, the Board is expected to respond to GAC advice from Helsinki and Hyderabad shortly - which includes GAC advice on privacy/proxy issues. Nick Shorey:@Mary thanks for this. most helpful Mary Wong:You're most welcome! Carlton Samuels:Will Sec VI also contains specific data items to be recorded and reported for Compliance purposes? Carlton Samuels:Thanks for the response. Carlton Samuels:Good suggestion Steve. Carlton Samuels:Question, how would the Transfer Policy of Dec 1 impact this? Mary Wong:@Carlton, none of this would change the 1 Dec effective date - however, to the extent that the Board subsequently agrees to the GNSO request to put the privacy/proxy aspect to our IRT, I believe that Compliance will allow for that flexibility. Alex Deacon:Maybe Graeme can describe what other alternatives were discussed? Vicky Sheckler:i'd be interested in understanding hte alternatives for where the issue can be addressed so as not to slow down the work of the work in this group Carlton Samuels:@Mary: Thanks. Look at the comments from this article concerning whois handling. Is that a legit issue? Carlton Samuels:https://urldefense.proofpoint.com/v2/url?u=http-3A__domainnamewire.… Graeme Bunton:Alex - I don't want to eat this call up on that issue, but if there is time at the end? Graeme Bunton:or maybe the RrSG could host a chat with IPC on this? Luc Seufer:Do we have LEA reps on this WG? (and not just US ones) Graeme Bunton:Nick Shorey is from UK LEA Alex Deacon:Thanks Graeme - just curious that other alternatives were discussed. I don't object per se but want to make sure it doesn't delay existing work.... Luc Seufer:it would be good to have some from Asia... where the language can be a barrier for PPSAI providers to handle requests Mary Wong:If it helps, any request from the Board/GNSO to handle the privacy/proxy aspects of IRTP within our IRT will be strictly bounded as such - any new or additional policy issues that may arise in the course of doing so will not be for the IRT to solve; ICANN's existing Consensus Policy Implementation Framework allows for how that will be handled e.g. referral back to the GNSO for policy work. Carlton Samuels:Thanks all. Bye Sara Bockey:thanks all Philip Corwin:bye all Tom Kinstler:THanks all Chris Pelling:Many thanks :) Alex Deacon:Thanks! Nick Shorey:Thanks! Luc Seufer:bye

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Materials, recording from PP IRT meeting on Nov. 29
by Amy Bivins Nov. 29, 2016

Nov. 29, 2016

Hi, everyone, Thanks so much for your attendance and active participation on our call today! Based on your feedback, we will push our future meetings an hour later to 15:00 UTC. I've attached: * The call chat transcript; * The slide deck from the call; * The v1 Policy outline document that we discussed on the call; and * The Policy recommendations summary document that I referenced on the call. [For those of you who were not on the call, this document summarizes the Policy recommendations from the Final Report. I organized the recommendations by category (noted on each tab) to hopefully make this easier to manage. Notes from the WG are highlighted in this sheet in yellow to distinguish notes from recommendations. There is no special meaning to the rows highlighted in blue-I just attempted to alternate colors of rows for each recommendation to make the sheet easier to read. Column B includes preliminary thoughts on the implementation mechanism for each recommendation, but this is preliminary thinking only and not an official staff position on how to best implement each recommendation.] The call recording is available at <https://participate.icann.org/p67o5hqw02q/?OWASP_CSRFTOKEN=24968d93bec2b482 0021b74197a309c4145c0ddf1faf4c0bbf36ff2e4f474d2b> https://participate.icann.org/p67o5hqw02q/ and will also be posted on the wiki. If you were unable to attend, I hope you are able to listen because we covered a lot of ground. Please provide your feedback on the draft Policy outline (or any other topic discussed during the call) no later than 12 December so that we can discuss it during our 13 December meeting. If you have questions or comments in the interim, please don't hesitate to reply to the list or contact me directly. I'll review the chat transcript and comments on the call to ensure we have accounted for all action items and outstanding questions. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Last call for input on privacy/proxy framework, ICANN57 materials
by Amy Bivins Nov. 14, 2016

Nov. 14, 2016

Hello, All, It was great to see those of you who were in Hyderabad, and I hope that everyone had a safe trip home. Materials from both the ICANN57 project overview session <https://community.icann.org/display/IRT/4+November+2016%3A+ICANN57+Privacy+ and+Proxy+Services+Accreditation+Overview+Session> and the IRT working meeting <https://community.icann.org/display/IRT/9+November+2016%3A+IRT+Working+Meet ing%2C+ICANN57> are available on the wiki. For those of you who could not attend, I encourage you to listen to the recordings. There was general agreement among those in attendance that the contract-based framework proposed for the accreditation of privacy and proxy services fulfills the intent of the Final Recommendations. We are leaving this topic open for your input until 28 November. If you have any further comments on this point, please send it to the list no later than that date. Provided no issues are raised on this approach, we will begin digging into the substance of this project on our next call, scheduled for 14:00 UTC on 29 November. We will be distributing an invitation shortly, and a more detailed agenda prior to our call. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Agenda, Login information for ICANN57 Privacy/Proxy IRT Working Meeting, 9 Nov, 11am local time
by Amy Bivins Nov. 5, 2016

Nov. 5, 2016

Hi Everyone, The slides for the Privacy and Proxy Services Accreditation Implementation Review Team working meeting at ICANN57 (at 11am local time), are now available on the meeting page (and are attached), https://icann572016.sched.org/event/8dQg/privacy-and-proxy-services-accredit ation-program-implementation-review-team-working-meeting. Here is the remote login information: Wednesday November 9, 2016 11:00 - 12:15 Adobe Connect <https://participate.icann.org/hyd57-hall6> https://participate.icann.org/hyd57-hall6 English Audio <http://stream.icann.org:8000/hyd57-hall6-en.m3u> http://stream.icann.org:8000/hyd57-hall6-en.m3u English Audio (Low Bitrate) <http://stream.icann.org:8000/hyd57-hall6-en-lo.m3u> http://stream.icann.org:8000/hyd57-hall6-en-lo.m3u Our agenda is as follows: >Project status >Summary of initial feedback >Discussion topic 1: Regular meeting day/time >Discussion topic 2: Contract-based framework proposal >Discussion topic 3: Project timeline >Next Steps (and request for any final feedback on contract-based approach no later than 28 November) I look forward to seeing those of you who are in Hyderabad, and hope that many of you who are not in Hyderabad can log in for the meeting. Materials and recordings will be posted afterward. In addition, the recording of the overview session from yesterday is now available (the first three minutes are silent due to technical issues with the audio): * Adobe Connect <https://participate.icann.org/p93vv787e5h/> Multimedia Session Recording * English Audio <http://audio.icann.org/meetings/hyd57/hyd57-OPEN-2016-11-04-T0519-hall3-tIe LQofAjV94kxTPq9LJXzD0QgvNTA1m-en.m3u> Session Recording Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org

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DOODLE POLL for Privacy and Proxy Service Accreditation Implementation IRT
by Michelle DeSmyter Nov. 5, 2016

Nov. 5, 2016

Dear All, Please fill out the following doodle poll below as soon as you are able so we can determine the time and frequency of our future Privacy and Proxy Service Accreditation Implementation IRT Meetings. http://doodle.com/poll/ayhmucfvipkqki9s Thank you so very much! Kind regards, Michelle DeSmyter

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Re: [Gdd-gnso-ppsai-impl] [Ntfy-gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework
by Amy Bivins Oct. 27, 2016

Oct. 27, 2016

Steve, Thanks so much for your feedback! All--I attached the annex to the PDF using Acrobat Pro's attachment feature, but it may not have been accessible to non-Pro users. I've attached it here (I also updated the attachment to correct a typo and to add gridlines to make this easier to read) and will also upload to the wiki. Also, all, this is a reminder that we hope to receive at least preliminary feedback from you by our Friday deadline so that we can incorporate it into our presentations and discussion plans for ICANN57. And if anyone would like to participate on the Panel on Friday the 4th, we are still looking for volunteers. I sent around invites for our sessions at ICANN57, and will update them later this week with agendas and specific discussion items, if any. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org From: Metalitz, Steven [mailto:met@msk.com] Sent: Monday, October 24, 2016 3:06 PM To: Amy Bivins <amy.bivins(a)icann.org>; ntfy-gdd-gnso-ppsai-impl(a)icann.org Subject: RE: [Ntfy-gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework Amy, thanks for circulating this material. Sorry I could not make the call last week, and apologies if the question below was addressed there. The explanatory memorandum refers twice to an Annex 1 (see nn.2 and 4). But no Annex 1 was attached and I was not able to find it on the Wiki page. Could you point me to it please? Regarding the questions you posed, I don't have any reason to think that the timeline you propose is too aggressive, but look forward to hearing from others on the IRT who may have a different view. Steve Metalitz Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | <mailto:met@msk.com> met(a)msk.com Mitchell Silberberg & Knupp LLP | <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.msk.com_&d=DQMF-g&c =FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgt dWrvLyZDu0mXuk&m=tFoUhidfLaFcINaq6aYfUMyas12P2vpFaQcMcogVBvE&s=j0oB8rlgXATJx VO9IsQo3uxBAJftu1lk7Y9eK2vg15Q&e=> www.msk.com[msk.com] 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: ntfy-gdd-gnso-ppsai-impl-bounces(a)icann.org [mailto:ntfy-gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, October 18, 2016 4:16 PM To: ntfy-gdd-gnso-ppsai-impl(a)icann.org Subject: [Ntfy-gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework Hello, All, Thanks so much for attending our Privacy and Proxy Services Accreditation Program Implementation Review Team kickoff call today. I'm attaching the slides from our call. Michelle distributed the call recording, chat transcript, and attendee list a short time ago. These will also be available on the wiki, https://community.icann.org/display/IRT/Privacy+and+Proxy+Services+Accredita tion+Implementation[community.icann.org] <https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_di splay_IRT_Privacy-26-2343-3Band-26-2343-3BProxy-26-2343-3BServices-26-2343-3 BAccreditation-26-2343-3BImplementation&d=DQMF-g&c=FmY1u3PJp6wrcrwll3mSVzgfk bPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bgtdWrvLyZDu0mXuk&m=tFoUhidfL aFcINaq6aYfUMyas12P2vpFaQcMcogVBvE&s=9AJPcYKQpSME9A4OoPccpz0hOhD_mLfhceS0kqF vzgQ&e=> . If you have any issues receiving or sending communications using this email list, please let me know. I'm also attaching the first discussion draft of the Privacy/Proxy Services Accreditation Program Framework, which I sent around to the list last week. Please review this document when you are able and provide your feedback, questions, concerns, etc no later than 28 October 2016. This deadline is to ensure that your initial feedback can be worked into presentations/planned discussion agendas at ICANN57. Specifically, ICANN seeks IRT feedback on whether you believe this proposed approach delivers on the intent of the Final Recommendations. A few notes from the call >Two IRT volunteers expressed concerns about the aggressiveness of the timeline. Staff requests specific feedback from the IRT regarding what elements of the plan seem too aggressive and/or should be revisited (and why). >One IRT volunteer expressed a positive view of the timeline >One IRT volunteer questioned whether this implementation will need to be complete before the next round of new gTLDs >Multiple IRT volunteers cautioned about the need to consider international data privacy and other laws throughout this implementation. Staff committed to a continued assessment of data privacy issues throughout this process. Next Steps >Two sessions are scheduled at this topic for ICANN57-a presentation of the overall proposal and an IRT working meeting. Staff is looking for volunteers for the IRT to participate in the "presentation" session and we hope that all of you can attend the working meeting but for those who can't, materials and recordings will be posted. >It was proposed that we have regularly scheduled IRT meetings. We will discuss preferred dates/times/schedule at our next meeting at Hyderabad and then will set up the regular meetings. Thanks again, and please feel free to weigh in on the list if there are other items you would like to highlight for those who could not attend the kickoff call. Best, Amy E. Bivins Registrar Policy Services 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[icann.org] <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=DQMF-g& c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-TplkjKTey9bg tdWrvLyZDu0mXuk&m=tFoUhidfLaFcINaq6aYfUMyas12P2vpFaQcMcogVBvE&s=siMT3PGRF7u3 RmqTH8SXTIVBz8zLd1x6eeufNZOLCvA&e=>

5 6

FW: [Ntfy-gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework
by Metalitz, Steven Oct. 24, 2016

Oct. 24, 2016

Re-sending as my original reply to Amy and the list was rejected. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: Metalitz, Steven Sent: Monday, October 24, 2016 3:06 PM To: 'Amy Bivins'; ntfy-gdd-gnso-ppsai-impl(a)icann.org Subject: RE: [Ntfy-gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework Amy, thanks for circulating this material. Sorry I could not make the call last week, and apologies if the question below was addressed there. The explanatory memorandum refers twice to an Annex 1 (see nn.2 and 4). But no Annex 1 was attached and I was not able to find it on the Wiki page. Could you point me to it please? Regarding the questions you posed, I don't have any reason to think that the timeline you propose is too aggressive, but look forward to hearing from others on the IRT who may have a different view. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met(a)msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: ntfy-gdd-gnso-ppsai-impl-bounces(a)icann.org<mailto:ntfy-gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:ntfy-gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, October 18, 2016 4:16 PM To: ntfy-gdd-gnso-ppsai-impl(a)icann.org<mailto:ntfy-gdd-gnso-ppsai-impl@icann.org> Subject: [Ntfy-gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework Hello, All, Thanks so much for attending our Privacy and Proxy Services Accreditation Program Implementation Review Team kickoff call today. I'm attaching the slides from our call. Michelle distributed the call recording, chat transcript, and attendee list a short time ago. These will also be available on the wiki, https://community.icann.org/display/IRT/Privacy+and+Proxy+Services+Accredit…. If you have any issues receiving or sending communications using this email list, please let me know. I'm also attaching the first discussion draft of the Privacy/Proxy Services Accreditation Program Framework, which I sent around to the list last week. Please review this document when you are able and provide your feedback, questions, concerns, etc no later than 28 October 2016. This deadline is to ensure that your initial feedback can be worked into presentations/planned discussion agendas at ICANN57. Specifically, ICANN seeks IRT feedback on whether you believe this proposed approach delivers on the intent of the Final Recommendations. A few notes from the call >Two IRT volunteers expressed concerns about the aggressiveness of the timeline. Staff requests specific feedback from the IRT regarding what elements of the plan seem too aggressive and/or should be revisited (and why). >One IRT volunteer expressed a positive view of the timeline >One IRT volunteer questioned whether this implementation will need to be complete before the next round of new gTLDs >Multiple IRT volunteers cautioned about the need to consider international data privacy and other laws throughout this implementation. Staff committed to a continued assessment of data privacy issues throughout this process. Next Steps >Two sessions are scheduled at this topic for ICANN57-a presentation of the overall proposal and an IRT working meeting. Staff is looking for volunteers for the IRT to participate in the "presentation" session and we hope that all of you can attend the working meeting but for those who can't, materials and recordings will be posted. >It was proposed that we have regularly scheduled IRT meetings. We will discuss preferred dates/times/schedule at our next meeting at Hyderabad and then will set up the regular meetings. Thanks again, and please feel free to weigh in on the list if there are other items you would like to highlight for those who could not attend the kickoff call. Best, Amy E. Bivins Registrar Policy Services 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 Overview Session at ICANN57
by Amy Bivins Oct. 20, 2016

Oct. 20, 2016

0 *H÷ 010 +0 *H÷ $·Content-Type: multipart/mixed; boundary="----=_NextPart_000_01BD_01D22AE1.93C19030" X-MS-TNEF-Correlator: F093D21A032BD201 This is a multipart message in MIME format. ------=_NextPart_000_01BD_01D22AE1.93C19030 Content-Type: text/plain; charset="us-ascii" Content-Transfer-Encoding: 7bit Hello, All, Please take note of the scheduled date and time for the Privacy and Proxy Services Accreditation Program IRT overview session at ICANN57 in Hyderabad. This meeting is scheduled for 4 November 2016, at 11:00-12:15 local time. * Adobe Connect <https://participate.icann.org/hyd57-G1> https://participate.icann.org/hyd57-G1 * English Audio <http://stream.icann.org:8000/hyd57-G1-en.m3u> http://stream.icann.org:8000/hyd57-G1-en.m3u * English Audio (Low Bitrate) <http://stream.icann.org:8000/hyd57-G1-en-lo.m3u> http://stream.icann.org:8000/hyd57-G1-en-lo.m3u We plan to cover much of the same material we covered on our kickoff IRT call for the broader community, and I plan to incorporate initial feedback from the IRT (so please send it by next Friday, the 28th). This session will be recorded and the recording will be posted shortly after the meeting. We are looking for some IRT members to participate-I hope that one or more of you can do so. Please contact me if you would like to discuss. I'll send you a more detailed agenda and materials before the meeting. Best, Amy Amy E. 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Re: [Gdd-gnso-ppsai-impl] [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework
by gdd-gnso-ppsai-impl＠icann.org Oct. 19, 2016

Oct. 19, 2016

Hi, All, Yesterday, I gave you the wrong address for the IRT email list (I thought the "ntfy" and the other list are the same, but the ntfy one is for calendar invites). I apologize for this mistake, and I have updated the address in the slide deck. To email the group and provide comments, please email gdd-gnso-ppsai-impl(a)icann.org. Per the recommendation on yesterday's call to set up regular meetings, we will be sending out a Doodle poll to find the most preferred time to begin biweekly meetings, starting the week of 28 November. If you have any questions or concerns, please don't hesitate to contact me, and we look forward to receiving your initial feedback on these documents no later than 28 October. We will also send invites for the meetings in Hyderabad once the days/times are final. Best, Amy Amy E. Bivins Registrar Policy Services 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 www.icann.org From: Amy Bivins Sent: Tuesday, October 18, 2016 4:16 PM To: ntfy-gdd-gnso-ppsai-impl(a)icann.org Subject: [Please respond by 28 Oct] Discussion Draft: Privacy/Proxy Services Accreditation Program Framework Hello, All, Thanks so much for attending our Privacy and Proxy Services Accreditation Program Implementation Review Team kickoff call today. I'm attaching the slides from our call. Michelle distributed the call recording, chat transcript, and attendee list a short time ago. These will also be available on the wiki, https://community.icann.org/display/IRT/Privacy+and+Proxy+Services+Accredita tion+Implementation. If you have any issues receiving or sending communications using this email list, please let me know. I'm also attaching the first discussion draft of the Privacy/Proxy Services Accreditation Program Framework, which I sent around to the list last week. Please review this document when you are able and provide your feedback, questions, concerns, etc no later than 28 October 2016. This deadline is to ensure that your initial feedback can be worked into presentations/planned discussion agendas at ICANN57. Specifically, ICANN seeks IRT feedback on whether you believe this proposed approach delivers on the intent of the Final Recommendations. A few notes from the call >Two IRT volunteers expressed concerns about the aggressiveness of the timeline. Staff requests specific feedback from the IRT regarding what elements of the plan seem too aggressive and/or should be revisited (and why). >One IRT volunteer expressed a positive view of the timeline >One IRT volunteer questioned whether this implementation will need to be complete before the next round of new gTLDs >Multiple IRT volunteers cautioned about the need to consider international data privacy and other laws throughout this implementation. Staff committed to a continued assessment of data privacy issues throughout this process. Next Steps >Two sessions are scheduled at this topic for ICANN57-a presentation of the overall proposal and an IRT working meeting. Staff is looking for volunteers for the IRT to participate in the "presentation" session and we hope that all of you can attend the working meeting but for those who can't, materials and recordings will be posted. >It was proposed that we have regularly scheduled IRT meetings. We will discuss preferred dates/times/schedule at our next meeting at Hyderabad and then will set up the regular meetings. Thanks again, and please feel free to weigh in on the list if there are other items you would like to highlight for those who could not attend the kickoff call. Best, Amy E. Bivins Registrar Policy Services 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 www.icann.org

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Attendance, AC Chat & AC Recording from Privacy and Proxy Services Accreditation IRT Kickoff Meeting
by gdd-gnso-ppsai-impl＠icann.org Oct. 18, 2016

Oct. 18, 2016

Dear All, Please find the attendance of the call attached to this email and the AC recording below for the Privacy and Proxy Services Accreditation IRT Kickoff Meeting held on Tuesday, 18 October 2016 at 18:00 UTC. Attendance of the calls is also posted on the agenda wiki page: https://community.icann.org/x/eR24Aw AC Recording: https://participate.icann.org/p8x5epar8ue/ ** Please let me know if your name has been left off the list ** Thank you. Kind regards, Michelle ------------------------------- Adobe Connect chat transcript for Tuesday, 18 October 2016 Michelle DeSmyter:Dear All, Welcome to the Privacy and Proxy Services Accreditation IRT Kickoff Meeting on Tuesday, 18 October 2016 at 18:00 UTC. Michelle DeSmyter:Wiki page: https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_x_… Chris Pelling:Good evening all Tom Kinstler:Good evening. Chris Pelling:Can we make the chat window bigger please ? Leana Vitruk:Hello Amy Bivins:Did that help, Chris? Chris Pelling:Thanks - thats a little better :) Tom Kinstler:We seem to have quite a bit of interference on the lines Chris Pelling:Yes I can now see 3 lines :) Amy Bivins:sorry, trying to not completely lose the slides Chris Pelling:@Amy, sometimes it is better to put the chat window as a block on the left hand side and have slides in middle Chris Pelling:or make the Notes smaller as the width is quite a but Amy Bivins:ok, I'll try to improve things for our next call if I can't get it sorted this time :) Chris Pelling:WOW thats better :) :) :) Amy Bivins:ok, great! Chris Pelling:Yes much better Amy - thank you :) Amy Bivins:you are very welcome Sarah Wyld:Hi! Tom Kinstler:Are we ready to begin? Graeme Bunton:Hello All Chris Pelling:Hi Graeme :) Jennifer Gore:hello all. thanks for joining us today Chris Pelling:Hey Jenn Sarah Wyld:Can you hear Amy? I cannot Alicia Kaelin:Is Amy muted? Chris Pelling:I cant hear anyone, just lots of what sounds like paper shuffling Alex Deacon:I'm not hearing any audio? talker on mute maybe? Graeme Bunton:Thought it was just me... Chris Pelling:I can hear birds :) Michele Neylon:evening Amy Bivins:am I still muted? Graeme Bunton:I hear birds chirping Tom Kinstler:Just hearing some birds Chris Pelling:evening Michele Graeme Bunton:it's delightfully pastoral Chris Pelling:aha voices :) Chris Pelling:yes Tom Kinstler:Yes Eric Rokobauer:yep! Shawn White:There is no audio on the adobe connect Tom Kinstler:Much bette Michele Neylon:desemobied voices Mary Wong:The Council will appoint a liaison shortly, hopefully at ICANN57. Michele Neylon:new councillors seated at ICANN57 Mary Wong:Yes, that's why IRT liaison appointments won't be done till after that happens. Michele Neylon:I know :) Michele Neylon:I'd have an issue with people NOT submitting an SOI Chris Pelling:@staf : can we make the slide a little larger pleaes ? Susan Kawaguchi:I am not sure I received these documents as I joined the IRT on Friday can you send them to me? Chris Pelling:staff* Chris Pelling:Please Michele Neylon:I didn't get any docs Chris Pelling:great ta :) Michele Neylon:I checked Michele Neylon:ok Outlook sucks and has taken to eating docs Michele Neylon:so I now have the doc :) Chris Pelling:question : can we have a link to the 1999 document please ? Michele Neylon:I don't know what this 1999 policy is Amy Bivins:https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_r… Michele Neylon:sorry - old hand Mary Wong:Please mute your mic if you're not speaking; thanks! Michele Neylon:1 - I'm muted - 2 - I'm not typing Graeme Bunton:I think it's an aggressive timeline Michele Neylon:you just love my dulcet tones Graeme Bunton:but sure, let's giv'er Chris Pelling:Quetsion : Why are we putting in a timeline that is so aggresive, is there a reason ? I mean, lots of things going on at the moment, ThickWHOIS, RDS et cetc Chris Pelling:you have lots of staff available to do lots of these PDPs/IRTs yet we dont have as many registrars as we are busy with other tasks Chris Pelling:other tasks meaning, IRTs etc that we have to complete and timeliness Chris Pelling:For example the tuesday meeting was good every week Chris Pelling:and if we dont need it cancel it Chris Pelling:at elast its in a diary Michele Neylon:Chris - exactly Chris Pelling:who agreed the timeline ? Chris Pelling:question above Michele Neylon:Chris - nobody - it's a proposal Mary Wong:@Chris, that is the intial proposal, so yes, feedback on whether it is feasible will be vety welcome. Michelle DeSmyter:https://urldefense.proofpoint.com/v2/url?u=https-3A__community.ica… Amy Bivins:https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann… Michele Neylon:Susan - I've sent it to you Susan Kawaguchi:Thanks Michele! Chris Pelling:No probs :-) Carlton Samuels:Howdy all. Mya apologies. Got held in a work meeting Mary Wong:The IRT can build in milestones and "time checks" into its Work Plan, maybe review this after a period of time. Chris Pelling:Amy can you put that sheet up please ? slide I mean Chris Pelling:yes thanks :) Michele Neylon:my dinner is cooking away happily so I'm good :) Chris Pelling:Just a thought with other things going on, this will need to be compatible with RDS and EY law ? Chris Pelling:EU * Mary Wong:Are IRT members planning to attend the IRT meeting in Hyderabad, in person or remotely? Chris Pelling:Me - remotely Graeme Bunton:Depending on schedule conflicts, I'll be there Mary Wong::) Michele Neylon:I'll be there in person Michele Neylon:but I don't know about conflicts Susan Kawaguchi:If I get a visa I will be there in person Carolyn Mitchell:I will be remote Michele Neylon:My passport is in the embassy as of today Carlton Samuels:I plan to be in Hyderabad principally for CCT RT. So long as no conflicts with my primary commitments I will be available Sara Bockey:I'll be there in person - barring conflicts Janelle McAlister:I just got my visa so I will be there in person Eric Rokobauer:Waiting for passport to come back to me as I plan to be there in person (first timer too!) Lisa Villeneuve:I will attend remotely Carlton Samuels:@Michele: Whaddya know, they have my passport since last Thursday! The Indian High Commission is just across the street from my yard. Michele Neylon:I'm hoping that I'll get it back with the correct visa this week Tom Kinstler:Will be remote, have prior commitments Michele Neylon:*fingers crossed* Alex Deacon:I'll be in Hyderabad in person.... Michele Neylon:Alex - we need to find decent local beer :) Tom Kinstler:Question: with regards to legal impact of the outcomes of these meetings, will we have input from international law experts? Alex Deacon:@Michele yes...top priority obviously. Michele Neylon::) Sara Bockey:so it looks like the meetings are on the 4th and 9th of Nov...is that correct? Chris Pelling:we will need to have EU legal involved Tom Kinstler:Great Thank you Chris Pelling:Thanks Amy :) Carlton Samuels:Thanks all. Bya all Tom Kinstler:Thank you, Amy and all involved. Sara Bockey:thanks all Jennifer Gore:Thank you Amy, Thanks everyone for joining Lisa Villeneuve:Thanks Alicia Kaelin:Thanks Amy! Graeme Bunton:thanks all Michele Neylon:ciao Eric Rokobauer:thanks! Tom Kinstler:bye Susan Kawaguchi:Thanks all!

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