I agree 100%; the definitions are outdated and nonsensical.
There are proxy service providers whose details replace those of the underlying RNH. But registrars cannot screen out those. As a retail-focused registrar, we do not have resellers but many web agencies as direct customers who, for one reason or another, will appoint themselves as registrants instead of their clients. One can determine they are acting as a proxy only by browsing the website the domain name points to.
This is also true for law firms, holding companies etc.
For those registrations, registrars don’t know the identity of the underlying registrant.
And there are privacy service providers most often affiliated with registrars. Those will also publish the names of their entities used for the privacy service, but will most often publish an anonymised details that allow to contact the RNH without disclosing their identity.
For those registrations, registrars know the identity of the underlying registrant. And some standardisation of the disclosure process could be beneficial/possible.
Some examples:
However, I have yet to encounter the definition of privacy providers where the registrant’s name is still published.
See you all in Prague!
Luc
Thank you for your comments, Reg and Steve. We look forward to the IRT’s discussion on this as well.
Steve, Jessica Puccio will reach out to you separately about posting your comments in the document.
Best,
Jason
From: Reg Levy via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org>
Reply-To: "PPSAI IRT members, including observers" <gdd-gnso-ppsai-impl@icann.org>
Date: Wednesday, May 28, 2025 at 7:32 PM
To: "PPSAI IRT members, including observers" <gdd-gnso-ppsai-impl@icann.org>
Cc: Jessica Puccio <jessica.puccio@icann.org>, "steve@shinkuro.com" <steve@shinkuro.com>, Reg Levy <rlevy@tucows.com>
Subject: [Gdd-gnso-ppsai-impl] Re: PPSAI IRT: Accreditation Model Comments Due Friday 30 May
I agree with Steve that the definitions are woefully out of date but have reviewed the document and look forward to our conversation.
Reg
Reg Levy | Associate General Counsel – Domains
Tucows #MakingTheInternetBetter
UTC -8
On May 28, 2025, at 15:09, Steve Crocker via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:
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.
Please find a few reminders related to the current IRT task and next IRT session below.
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.
Please let us know if you have not received invitations for the June session.
We look forward to connecting in Prague.
Sr. Manager, Reviews and Stakeholder Support
Internet Corporation for Assigned Names and Numbers (ICANN)
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Jessica Puccio
Sr Coordinator, Review Support and Accountability Projects
Internet Corporation for Assigned Names and Numbers (ICANN)
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