I need help finding how to add my comments into the document. Here's what I want to add.

Privacy and Proxy providers provide different services, so my comments on them are distinct.

Proxy providers submit their own name as the Registrant. (The Registrant is also known as the Registered Name Holder (RNH).) The Proxy provider does not provide to the Registrar the name of the beneficial user of the domain name, thereby undermining the requirement that accurate information must be provided. This practice of using proxy providers arose prior to the GDPR because Registrars did not restrict access to registration data. Registrars are now required to protect the privacy of Registrants, so there is no longer a legitimate purpose for Proxy providers.

Registrars should refuse registrations from known Proxy providers. If a registration is made from an unknown Proxy provider, the Registrar should treat the Proxy as the legal Registrant.

No accreditation of Proxy providers is required. Registrars do need to operate Proxy Providers. They can restrict access to the registration data in accordance with applicable laws and policies while maintaining accurate records.

Privacy providers provide a distinctly different service. They submit the accurate name of the Registrant but alternative contact information -- email address, phone and/or physical address. The purpose is to have communications from parties seeking to communicate with the Registrant directed to an intermediary instead of directly to the Registrant. This function can and should be provided in a more direct and visible fashion. Instead of putting alternative contact data into the data fields associated with the Registrant, there should be a new role defined for accepting correspondence, Correspondence. The Registrant's contact data should still be collected, but it need not be supplied to most Requestors. If the Correspondence role is populated with contact data, it should be returned to the Requestor and explicitly labeled as Correspondence contact data.

Thanks,

Steve Crocker

On Wed, May 28, 2025 at 2:55 PM Jessica Puccio via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:

Hello IRT,

Please find a few reminders related to the current IRT task and next IRT session below.

Current IRT Task

Please provide your input on the accreditation models document by Friday, 30 May. Thanks to all who have contributed already. You can find responses to the comments received thus far in the IRT comment tracker.

In reviewing your comments, we identified areas where language should be updated for consistency. These updates have been highlighted in yellow for the IRT’s reference.

Next IRT Session

The IRT’s next session will be held on Wednesday, 11 June 07:00 UTC at ICANN83. This session will focus on the input received on the accreditation models and next steps for the IRT’s work.

Please let us know if you have not received invitations for the June session.

We look forward to connecting in Prague.

Best,

Jason

Sr. Manager, Reviews and Stakeholder Support

Internet Corporation for Assigned Names and Numbers (ICANN)

www.icann.org

--

Jessica Puccio

Sr Coordinator, Review Support and Accountability Projects

Internet Corporation for Assigned Names and Numbers (ICANN)

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