Meeting follow-up | Scheduling of 24 July Meeting
Hello IRT, Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document<https://docs.google.com/document/d/1tyU2iLxwvvVJBTybUulXFnFCN600nMEu/edit>. As promised, we are sending out invitations for a meeting next Thursday, 24 July at 15:30 UTC to continue the discussion. Reminder: IRT input is needed by the end of the day Friday, 25 July. To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s). We will use your comments to guide the discussion. We look forward to seeing everyone next Thursday! Best, Jason Jason Kean Sr. Manager, Reviews and Stakeholder Support Internet Corporation for Assigned Names and Numbers (ICANN) www.icann.org<http://www.icann.org>
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. Sincerely, Volker Greimann General Counsel & Head of Policy and Compliance - Online Division volker.greimann@centralnic.com Office: +49-172-6367025 Web: www.teaminternet.com Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358. ________________________________ From: Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> Sent: 17 July 2025 11:28 PM To: gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl@icann.org> Cc: Jason Kean <jason.kean@icann.org> Subject: [Gdd-gnso-ppsai-impl] Meeting follow-up | Scheduling of 24 July Meeting Hello IRT, Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document<https://docs.google.com/document/d/1tyU2iLxwvvVJBTybUulXFnFCN600nMEu/edit>. As promised, we are sending out invitations for a meeting next Thursday, 24 July at 15:30 UTC to continue the discussion. Reminder: IRT input is needed by the end of the day Friday, 25 July. To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s). We will use your comments to guide the discussion. We look forward to seeing everyone next Thursday! Best, Jason Jason Kean Sr. Manager, Reviews and Stakeholder Support Internet Corporation for Assigned Names and Numbers (ICANN) www.icann.org<http://www.icann.org>
I like that! A possible problem is that this covers disclosure rules, but not disclosure processes. The Board made it clear that they would expect a future SSAD/RDRS to include P/P providers (at least the large corporate ones). A possible solution would be to incorporate that into the RAA provisions for registrar-affiliated P/P providers Alan On Thu, Jul 17, 2025 at 7:41 PM Volker Greimann via Gdd-gnso-ppsai-impl < gdd-gnso-ppsai-impl@icann.org> wrote:
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.
Sincerely,
*Volker Greimann* *General Counsel & Head of Policy and Compliance - Online Division*
volker.greimann@centralnic.com Office: +49-172-6367025 Web: www.teaminternet.com
Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358.
------------------------------ *From:* Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> *Sent:* 17 July 2025 11:28 PM *To:* gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl@icann.org> *Cc:* Jason Kean <jason.kean@icann.org> *Subject:* [Gdd-gnso-ppsai-impl] Meeting follow-up | Scheduling of 24 July Meeting
Hello IRT,
Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document <https://docs.google.com/document/d/1tyU2iLxwvvVJBTybUulXFnFCN600nMEu/edit> .
As promised, we are sending out invitations for a meeting next *Thursday, 24 July at **15:30 UTC* to continue the discussion. *Reminder*: IRT input is needed by the end of the day Friday, 25 July.
To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s).
We will use your comments to guide the discussion.
We look forward to seeing everyone next Thursday!
Best,
Jason
Jason Kean
Sr. Manager, Reviews and Stakeholder Support
Internet Corporation for Assigned Names and Numbers (ICANN)
www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list -- gdd-gnso-ppsai-impl@icann.org To unsubscribe send an email to gdd-gnso-ppsai-impl-leave@icann.org _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
One added thought. Passed-on requirements would probably also need to include option to not disclose, but assume full responsibility (ie be the registrant). On Thu, Jul 17, 2025 at 9:26 PM Alan Greenberg <greenberg.alan@gmail.com> wrote:
I like that!
A possible problem is that this covers disclosure rules, but not disclosure processes. The Board made it clear that they would expect a future SSAD/RDRS to include P/P providers (at least the large corporate ones). A possible solution would be to incorporate that into the RAA provisions for registrar-affiliated P/P providers
Alan
On Thu, Jul 17, 2025 at 7:41 PM Volker Greimann via Gdd-gnso-ppsai-impl < gdd-gnso-ppsai-impl@icann.org> wrote:
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.
Sincerely,
*Volker Greimann* *General Counsel & Head of Policy and Compliance - Online Division*
volker.greimann@centralnic.com Office: +49-172-6367025 Web: www.teaminternet.com
Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358.
------------------------------ *From:* Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org
*Sent:* 17 July 2025 11:28 PM *To:* gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl@icann.org> *Cc:* Jason Kean <jason.kean@icann.org> *Subject:* [Gdd-gnso-ppsai-impl] Meeting follow-up | Scheduling of 24 July Meeting
Hello IRT,
Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document <https://docs.google.com/document/d/1tyU2iLxwvvVJBTybUulXFnFCN600nMEu/edit> .
As promised, we are sending out invitations for a meeting next *Thursday, 24 July at **15:30 UTC* to continue the discussion. *Reminder*: IRT input is needed by the end of the day Friday, 25 July.
To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s).
We will use your comments to guide the discussion.
We look forward to seeing everyone next Thursday!
Best,
Jason
Jason Kean
Sr. Manager, Reviews and Stakeholder Support
Internet Corporation for Assigned Names and Numbers (ICANN)
www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list -- gdd-gnso-ppsai-impl@icann.org To unsubscribe send an email to gdd-gnso-ppsai-impl-leave@icann.org _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
+1 To me it was always a matter of understanding what lawyers in my area of the world label 'agency'. Why should I care about the one behind the veil, the motivations or otherwise when I know the perpetrator of the act, that guy who gave the veil? All I need to know is the authority to act for the guy behind the veil, expressed or implied. Why not hold the one I know to account? Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* ============================= On Thu, 17 Jul 2025 at 18:41, Volker Greimann via Gdd-gnso-ppsai-impl < gdd-gnso-ppsai-impl@icann.org> wrote:
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.
Sincerely,
*Volker Greimann* *General Counsel & Head of Policy and Compliance - Online Division*
volker.greimann@centralnic.com Office: +49-172-6367025 Web: www.teaminternet.com
Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358.
------------------------------ *From:* Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> *Sent:* 17 July 2025 11:28 PM *To:* gdd-gnso-ppsai-impl@icann.org <gdd-gnso-ppsai-impl@icann.org> *Cc:* Jason Kean <jason.kean@icann.org> *Subject:* [Gdd-gnso-ppsai-impl] Meeting follow-up | Scheduling of 24 July Meeting
Hello IRT,
Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document <https://docs.google.com/document/d/1tyU2iLxwvvVJBTybUulXFnFCN600nMEu/edit> .
As promised, we are sending out invitations for a meeting next *Thursday, 24 July at **15:30 UTC* to continue the discussion. *Reminder*: IRT input is needed by the end of the day Friday, 25 July.
To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s).
We will use your comments to guide the discussion.
We look forward to seeing everyone next Thursday!
Best,
Jason
Jason Kean
Sr. Manager, Reviews and Stakeholder Support
Internet Corporation for Assigned Names and Numbers (ICANN)
www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list -- gdd-gnso-ppsai-impl@icann.org To unsubscribe send an email to gdd-gnso-ppsai-impl-leave@icann.org _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Exactly this—and that is the registrant. -- Reg Levy | Associate General Counsel – Domains +1 (323) 880-0831 Tucows #MakingTheInternetBetter UTC -8
On Jul 18, 2025, at 15:42, Carlton Samuels via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org> wrote:
+1
To me it was always a matter of understanding what lawyers in my area of the world label 'agency'.
Why should I care about the one behind the veil, the motivations or otherwise when I know the perpetrator of the act, that guy who gave the veil?
All I need to know is the authority to act for the guy behind the veil, expressed or implied. Why not hold the one I know to account?
Carlton
============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround =============================
On Thu, 17 Jul 2025 at 18:41, Volker Greimann via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> wrote:
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.
Sincerely, Volker Greimann General Counsel & Head of Policy and Compliance - Online Division
volker.greimann@centralnic.com <mailto:volker.greimann@centralnic.com> Office: +49-172-6367025 Web: www.teaminternet.com <http://www.teaminternet.com/>
Team Internet Group PLC (AIM:TIG). Registered Office: 4th Floor, Saddlers House, 44 Gutter Lane, London, United Kingdom, EC2V 6BR. Team Internet is a company registered in England and Wales with the company number 8576358.
From: Jason Kean via Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> Sent: 17 July 2025 11:28 PM To: gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> <gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org>> Cc: Jason Kean <jason.kean@icann.org <mailto:jason.kean@icann.org>> Subject: [Gdd-gnso-ppsai-impl] Meeting follow-up | Scheduling of 24 July Meeting
Hello IRT,
Thank you all for the productive session earlier today on the draft PPSAI IRT Threshold Question document <https://docs.google.com/document/d/1tyU2iLxwvvVJBTybUulXFnFCN600nMEu/edit>.
As promised, we are sending out invitations for a meeting next Thursday, 24 July at 15:30 UTC to continue the discussion. Reminder: IRT input is needed by the end of the day Friday, 25 July.
To help prepare for this meeting, we ask that you make comments on any aspect of the document that you cannot live with and provide text that you could support in your comment(s).
We will use your comments to guide the discussion.
We look forward to seeing everyone next Thursday!
Best, Jason
Jason Kean
Sr. Manager, Reviews and Stakeholder Support
Internet Corporation for Assigned Names and Numbers (ICANN)
www.icann.org <http://www.icann.org/>_______________________________________________ Gdd-gnso-ppsai-impl mailing list -- gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> To unsubscribe send an email to gdd-gnso-ppsai-impl-leave@icann.org <mailto:gdd-gnso-ppsai-impl-leave@icann.org> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
Gdd-gnso-ppsai-impl mailing list -- gdd-gnso-ppsai-impl@icann.org To unsubscribe send an email to gdd-gnso-ppsai-impl-leave@icann.org _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
participants (5)
-
Alan Greenberg -
Carlton Samuels -
Jason Kean -
Reg Levy -
Volker Greimann