Agreed, if the provider is awol, then we should not expect much
from them.
Section 3.3.5 Without going into the operational challenges we
might/should make sure this section allows Registrars a lot of
flexibility here. I cautioned about the GDPR data breach
possibility, most likely ICANN as the data controller will be
liable here, but we should come up with something that makes sure
this does not happen. This might be a sub team task.
3.5 A privacy service is a service, not a domain name. Under the
current language, a customer can choose between privacy providers
without transferring the actual domain name. The same logic
applies when it comes to de-accreditation.
Section 5.
I am not going to belabor this point.
This procedure deals with domain names, where a Registrar gets
domain names transferred to its accreditation.
What is happening is that a domain name registrant contact gets
updated. An update to the WHOIS records at best.
5.4 Good to notice that ICANN will do all the work here.
To make this work detailed Escrow data for nonaffiliated providers
is key here.
De-Accredited Registrar Transition Procedure in general.
Tom Barret pointed out that this is in some cases, call it doing
the community a favor here. You might get 1000 domain names on
your accreditation really easy if you get some renewals out of it,
great, you made some money as a Registrar, though most likely you
did a ton of work and got paid peanuts in the end. But that is a
business decision or better put, you doing ICANN a favor and its
community and the registrants.
What I the privacy provider is offering the privacy service for
free? As the gaining privacy provider and you charge money you
know for sure that those customers are not going to renew, they
want out to another privacy provider that offers the service for
free.
If if the gaining privacy provider does provide the service for
free then this provider will do a ton of work for nothing, there
is nothing to gain except liability issues.
In fact, you have to verify, suspend domain names and your support
staff will go nuclear and not having a good week.
6
I expect there will be no pool of privacy providers. I have looked
at the DART program a few years back; I truly appreciate what Tom
Barret and other Registrars in that pool are doing.
But the reality it is an amazing boatload of work. Sometimes the
data quality is poor and requires a lot of scripting.