Hi Theo, Thank you for your comments thus far. To clarify for the group: Section 2.2--this section was appropriated from the RAA but modified. You'll notice that, unlike the comparable section in the RAA, there is no allowance for use of a logo in the PPAA draft (and there is no logo license specification in the PPAA as there is in the RAA). This section simply restricts how accredited providers can use the ICANN name and marks. Sections 3.5.4.3, 3.5.4.8--these sections were included in this draft as they appeared to be equally relevant to PP Providers. But if the IRT feels differently we can revisit. This will be added to the issues list. And same for the specifications. We took this approach in utilizing and adapting portions of the RAA because many of the sections are relevant and applicable to PP providers. It seemed to create less confusion to have identical (or nearly identical) provisions, so that registrars with PP affiliates would not be in a position of needing to understand and comply with different standards depending on the service (as this could be confusing). In many of our discussions so far, the IRT has also indicated that care should be taken to follow the RAA where possible. If sections/specifications need to be revisited and/or modified, that is what we are planning to do now, based on your feedback. As mentioned, we are planning to review this document topic by topic to make the discussion more manageable. I hope this helps and look forward to others' feedback. Best, Amy -----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 20, 2017 7:45 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call Hi Amy, et al. I read the document called PPAA_17July-CLEAN.pdf, aka the PPSAI accreditation agreement. And I am struggling with the approach here. Personally, I think there are too many sections from the RAA 2013 in there that makes this agreement hard to execute for privacy providers or impossible to comply with. A few examples. 2.2 Privacy Providers will be able to display the ICANN accredited logo on their website. A logo that is used by Registrars. Could this create confusion? Does ICANN ORG want this? Or will there be a new logo for privacy providers? 3.5.4.3 What does this section do? Is this for domain names or privacy services? 3.5.4.8 Can be removed; this is not applicable for privacy services? These minor examples continue through the entire document and you often wonder how will an NA-TPPP deal with this as they are in no position to meet these requirements. Page 48 contains data accuracy, validation, verification aka RAA 2013 WAPS, makes sense. But an NA-TPPP cannot suspend a domain name, most of these sections are not applicable. Spec 3, page 53 1.3.2 warehousing of registries and registrars? Page 68 Data retention specification, are we really going through a waiver process for privacy providers? Privacy providers will need to rely on Registrars when it comes to section 1.1.6. This happens a lot in the document. It reads like there is no good distinction between privacy offered as a service versus what a Registrar does? I did not read the entire document with full focus but rather skimmed it through but I suspect that it will take a lot of work and discussion to get this into shape and error free. So there are two tracks? Either setup an agreement from scratch? Also a lot of work, I guess, but most likely will be cleaner. The second track is, go through the agreement section by section and correct the errors or discuss the intent. This, in my opinion, will take longer. Thoughts? Theo Amy Bivins schreef op 2017-07-18 05:36 PM:
Hi, All,
Thanks so much for your attendance at the PP IRT call today.
As mentioned, next week, we plan to discuss:
* The data escrow specification in the draft PPAA (attached); * IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); * (Possibly) PPAA amendment process (will confirm by end of this week)
IRT ACTION ITEMS
* Review the draft data escrow specification and come to 25 July meeting prepared to discuss:
* Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers.
* Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks.
For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it.
If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached).
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
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