Hi all,

one thought: Would we not be able to circumvent all the issues with whether or not (and if so how) to accredit  pp providers with one simple hack?

The goal ultimately is to hold privacy providers accountable and ensure they fall (essentially) under the same rules for data disclosure as registrars do already, e.g ensuring that registrants are bound by terms that we understand pp providers should follow. This would cleanly avoid all bureaucratic overhead, avoid having to differentiate between affiliated or non-affiliated providers, etc. This can be done by a simple policy requirement that would require registrars to pass along certain terms to all registrants  through their agreements, gTAC, policies or otherwise.

Essentially it boils down to the essence of the matter that privacy service providers are just another type of registrants.

"Registrars must ensure that registrants using their services who register domain names for the sole use of, on behalf of or for the benefit of third parties agree to... ." should do nicely as a starting point as there is already precedent for such requirements in other policies. 

Maybe this could also be brought to the GNSO as an option when they address our concerns regarding the issues with the non-community developed accreditation models proposed by ICANN staff. 

Yes, this may require a rewrite of the existing policy recommendations, but the general principles stated above that were mostly agreed would form a basis that would allow quick progress. 

Volker Greimann
General Counsel & Head of Policy and Compliance - Online Division

volker.greimann@centralnic.com
Office: +49-172-6367025
Web: www.teaminternet.com

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