PP fees proposal document attached
Dear Colleagues, Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list. Thank you for your patience. 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<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>
Hi Amy, thank you for providing a brief moment of mirth amongst all the GDPR sadness these days. I appreciate the effort of ICANN finance trying to brighten our days with a little humor. With all due respect though, this document is comparing apples to oranges when they use registrar accreditation as a basis for the costing efforts. The businesses of a registrar, where the accreditation fees are a miniscule fraction of the benefits derived from the business arising from the accreditation, cannot be compared to the business of a privacy proxy service, which usually works on a break-even level or even below that (certain large services being the exception). I also regret that none of the arguments we made over the past months are even remotely considered by the drafter of this document. Here are the fees I would see as appropriate: Affiliated providers: 1000 USD accreditation fee, zero USD annual fees Non-Affiliated providers: 1500 USD accreditation fees, 500 USD annual fees. Any shortfall would be covered by the ICANN budget, resulting in the community paying for what they asked for. Further cost reductions can be achieved by: PP Application Evaluation Ops: 192,531 USD for internal evaluation of applications? With staff that is already being paid? Please detail what this cost comes from precisely. -Cutting the background check (the WG never made a recommendation requiring such a check, so if ICANN wants it, it should pay for it itself - providers get no benefit from these checks). There, I just saved you 631,790 USD. No need to thank me, gladly done! - Cutting overhead to 5%: ICANN should operate a bit more frugally. Waste costs should not be borne by providers. - Compliance: Compliance has publicly stated they do not expect to hire additional staff for this as in many cases registrar complaint ressources would be shifted to this. Stop adding cost where the team benefitting from it said it does not need it. I just saved you another 19,423 USD. - Renewals cost: Make the term of the accreditation agreement longer, set it to auto-renew unless terminated or do not set an end date at all with more open termination rules. - PP training: Create webinars and FAQs that can be viewed at leisure. - PP data escrow: Similar to registrar data escrow, this hit is taken out of the ICANN budget - community wants it, community pays for it. - Billing and collections: Can likely be taken on by existing staff as part of their daily routine work. Another 7,800 USD saved. I also note that contrary to the presentation at the last ICANN meeting, per unit prices would now fluctuate greatly depending on the number of accredited providers. I specifically asked whether there would be an impact depending on whether only 5 providers joined or 10,000 providers joind and was told there would be no effect. Seems that position has now changed? If ICANN goes forward with this plan, it will result in one of the biggest wastes of community time and the largest failed program as the number of providers that will undergo this program will be minimal (maybe countable on one hand), because GDPR is already providing most benefits to registrants that they would get under a privacy or proxy service. Godaddy has already announced it will no longer provide privacy services to those customers that they consider to fall under the GDPR protections, and Ia assume others will follow. So the need for a registrar or reseller to provide such a service will be significantly less urgent and demand for such services will significantly shrink. So by making it harder and costlier to operate such a service, ICANN has achieved the goal of encouraging domain registration service providers to stop offering these services and instead opt for providing maximum GDPR protection for free for all of their customers. This plan reads to me like an attempt to price smaller ppsp's out of the market. Enough already! Back to the drawing board! Best regards, Volker Am 22.05.2018 um 22:20 schrieb Amy Bivins:
Dear Colleagues,
Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list.
Thank you for your patience.
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 <mailto:amy.bivins@icann.org>
www.icann.org <http://www.icann.org>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
Thanks Amy, Am I reading this correctly? The program startup and application processing is going to cost; 1,117,390??? That is a huge amount of money for a program startup if only a few providers signup for this and the majority decides that the temporary spec or it's successor is enough privacy for registrants. But maybe I am reading it incorrectly. When I look at the Activity Relevant Department(s) Accredited Provider Account Management Services, it seems many of these activities already exist for Registrars. Can those activities not be handled by the same folks? I mean does it matter if a Registrar changes its name or a Privacy Provider? It's the same type of processing is it not? Also, a question about the PP Data Retention Waiver activity. What is this activity? Thanks, Theo Amy Bivins schreef op 2018-05-22 10:20 PM:
Dear Colleagues,
Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list.
Thank you for your patience.
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
www.icann.org [1]
Links: ------ [1] http://www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Dear Colleagues, Thank you for taking the time to review and provide feedback on the privacy and proxy service provider accreditation fees-related documentation, both on the list and during the meetings we have recently had on this topic. ICANN org has carefully considered the feedback of all IRT members in developing the proposed fee structure. Despite recommendations from some IRT members to reduce the proposed fees, ICANN org continues to believe that the fees proposed are reasonable and appropriate, for the reasons identified in the fees proposal documentation (attached). As noted in the fees proposal, ICANN org analyzed three relevant factors in reaching the fee structure that was proposed: relevant benchmarks; fees transparency, simplicity, stability and predictability; and anticipated program management costs. ICANN org understands that some IRT members disagree with this assessment, but did not find any of the arguments or suggestions raised by IRT members persuasive. If persuasive reasons are raised for revisiting the proposed fee structure during the public comment period, ICANN org commits to revisit the proposed fees. Please know that ICANN org sincerely appreciates the time and effort you committed to this exercise and the broader work of the IRT. Best, Amy -----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Wednesday, May 23, 2018 10:04 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] PP fees proposal document attached Thanks Amy, Am I reading this correctly? The program startup and application processing is going to cost; 1,117,390??? That is a huge amount of money for a program startup if only a few providers signup for this and the majority decides that the temporary spec or it's successor is enough privacy for registrants. But maybe I am reading it incorrectly. When I look at the Activity Relevant Department(s) Accredited Provider Account Management Services, it seems many of these activities already exist for Registrars. Can those activities not be handled by the same folks? I mean does it matter if a Registrar changes its name or a Privacy Provider? It's the same type of processing is it not? Also, a question about the PP Data Retention Waiver activity. What is this activity? Thanks, Theo Amy Bivins schreef op 2018-05-22 10:20 PM:
Dear Colleagues,
Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list.
Thank you for your patience.
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
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=BJtpG8Olp_3NAmSVAsUTW_HmMsKblc3_3k59uUScn vs&s=YBcBo-2U5vstASdpDcav-4W8w712XbFjerD180TrPRo&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Amy, If there is no counter argument why do we provide feedback in the first place? Were the arguments not valid, not good enough? I still see a program startup, that will cost over a million, and that does not make sense to me post GDPR with a redacted WHOIS for 23+ days. Thanks, Theo On 13-6-2018 19:11, Amy Bivins wrote:
Dear Colleagues,
Thank you for taking the time to review and provide feedback on the privacy and proxy service provider accreditation fees-related documentation, both on the list and during the meetings we have recently had on this topic.
ICANN org has carefully considered the feedback of all IRT members in developing the proposed fee structure. Despite recommendations from some IRT members to reduce the proposed fees, ICANN org continues to believe that the fees proposed are reasonable and appropriate, for the reasons identified in the fees proposal documentation (attached).
As noted in the fees proposal, ICANN org analyzed three relevant factors in reaching the fee structure that was proposed: relevant benchmarks; fees transparency, simplicity, stability and predictability; and anticipated program management costs. ICANN org understands that some IRT members disagree with this assessment, but did not find any of the arguments or suggestions raised by IRT members persuasive.
If persuasive reasons are raised for revisiting the proposed fee structure during the public comment period, ICANN org commits to revisit the proposed fees. Please know that ICANN org sincerely appreciates the time and effort you committed to this exercise and the broader work of the IRT.
Best,
Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Wednesday, May 23, 2018 10:04 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] PP fees proposal document attached
Thanks Amy,
Am I reading this correctly? The program startup and application processing is going to cost; 1,117,390??? That is a huge amount of money for a program startup if only a few providers signup for this and the majority decides that the temporary spec or it's successor is enough privacy for registrants. But maybe I am reading it incorrectly.
When I look at the Activity Relevant Department(s) Accredited Provider Account Management Services, it seems many of these activities already exist for Registrars. Can those activities not be handled by the same folks? I mean does it matter if a Registrar changes its name or a Privacy Provider? It's the same type of processing is it not?
Also, a question about the PP Data Retention Waiver activity. What is this activity?
Thanks,
Theo
Amy Bivins schreef op 2018-05-22 10:20 PM:
Dear Colleagues,
Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list.
Thank you for your patience.
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
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=BJtpG8Olp_3NAmSVAsUTW_HmMsKblc3_3k59uUScn vs&s=YBcBo-2U5vstASdpDcav-4W8w712XbFjerD180TrPRo&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
So basically ICANN is taking it upon itself to overrule the IRT concerns on this. Very interesting. What are we here for then? If this is how the post-transition ICANN operates, maybe we should have another look at the ITU... Volker Am 13.06.2018 um 19:11 schrieb Amy Bivins:
Dear Colleagues,
Thank you for taking the time to review and provide feedback on the privacy and proxy service provider accreditation fees-related documentation, both on the list and during the meetings we have recently had on this topic.
ICANN org has carefully considered the feedback of all IRT members in developing the proposed fee structure. Despite recommendations from some IRT members to reduce the proposed fees, ICANN org continues to believe that the fees proposed are reasonable and appropriate, for the reasons identified in the fees proposal documentation (attached).
As noted in the fees proposal, ICANN org analyzed three relevant factors in reaching the fee structure that was proposed: relevant benchmarks; fees transparency, simplicity, stability and predictability; and anticipated program management costs. ICANN org understands that some IRT members disagree with this assessment, but did not find any of the arguments or suggestions raised by IRT members persuasive.
If persuasive reasons are raised for revisiting the proposed fee structure during the public comment period, ICANN org commits to revisit the proposed fees. Please know that ICANN org sincerely appreciates the time and effort you committed to this exercise and the broader work of the IRT.
Best,
Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Wednesday, May 23, 2018 10:04 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] PP fees proposal document attached
Thanks Amy,
Am I reading this correctly? The program startup and application processing is going to cost; 1,117,390??? That is a huge amount of money for a program startup if only a few providers signup for this and the majority decides that the temporary spec or it's successor is enough privacy for registrants. But maybe I am reading it incorrectly.
When I look at the Activity Relevant Department(s) Accredited Provider Account Management Services, it seems many of these activities already exist for Registrars. Can those activities not be handled by the same folks? I mean does it matter if a Registrar changes its name or a Privacy Provider? It's the same type of processing is it not?
Also, a question about the PP Data Retention Waiver activity. What is this activity?
Thanks,
Theo
Amy Bivins schreef op 2018-05-22 10:20 PM:
Dear Colleagues,
Attached, you will find additional information related to the proposed fees for the privacy and proxy service provider accreditation program. Please review and send any comments/questions to the list.
Thank you for your patience.
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
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=BJtpG8Olp_3NAmSVAsUTW_HmMsKblc3_3k59uUScn vs&s=YBcBo-2U5vstASdpDcav-4W8w712XbFjerD180TrPRo&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
participants (4)
-
Amy Bivins -
gtheo -
theo geurts
-
Volker Greimann