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@icann.org