Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
Dear Colleagues, Thanks so much for your active participation on yesterday's Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017 As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide: (1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached). (2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report. As you are reviewing these documents, please consider the following questions: (a) Is this proposed process consistent with the intent of the Policy recommendations? (b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations? (c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? (d) Are there processes/criteria that may require "implementation adjustment" (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? (e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? Next week's meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May. If you have questions or comments between now and then, please don't hesitate to reply to the list or contact me directly. 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>
Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week’s meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don’t hesitate to reply to the list or contact me directly.
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>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Thanks for preparing these additional documents, Amy. One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant's standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a "business registration certificate" as a "required appendix" -so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in "documentation demonstrating that the Applicant entity is legally established and in good standing", to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities? I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, May 23, 2017 12:13 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday's Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017<https://community.icann.org/display/IRT/16+May+2017>
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require "implementation adjustment" (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week's meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don't hesitate to reply to the list or contact me directly.
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<mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org>> www.icann.org<http://www.icann.org><http://www.icann.org<http://www.icann.org>>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl>
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl<https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl>
Thank you Amy for providing the documentation for review. Please find some remarks and thoughts on the questions presented. *Referencing the comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation.* - Why is some of the draft P/P application reorganized from what is used for registrars? For instance, line 2 has legal for form of applicant for registrars, but that seems to be missing for P/P providers. Not sure of the reason for these differences. - A.1 for the P/P draft has a note stating "combination of Rr APP Qs 1 and 4". What was the reasoning there? - Regarding line 5 - do we not intend to ask for documentation of good standing for P/P providers the way we do for registrars? Was it not the PPSAI PDP WG intention to hold the P/P providers to the same accreditation standards as registrars? - Leading into comments below, might work to start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline. *Referencing the annotated version of the draft v1 application for privacy/proxy service provider accreditation.* - 12 months makes sense for a timeline. I remember one comment came up during our last call inquiring if ICANN would take applications before month 3 when application window starts. Any update there? - Is there interest in reducing the application window itself (between month 3 and 6)? Less time to apply, but quicker turnaround for all? Interested for thoughts here from IRT. *As you are reviewing these documents, please consider the following questions:* *(a) Is this proposed process consistent with the intent of the Policy recommendations?* Yes, but the misalignment of requirements (line by line) between the current registrar application and the p/p draft makes this difficult to compare the two. Can we realign or display in a different manner? *(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?* This was something I had called out in our last call. Certain questions specifically associated to registrar operations (data escrow, registrant validation/verification) should be sectioned together. If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided. *(d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?* Yes. Unaffiliated P/P providers need to complete the full application with all requirements for operation answered. *(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?* Yes. Primarily those that looked to have been designed for registrar operations. Details that P/P provider applicants may not necessarily be privy to. - D.2 - Length of time already providing service. How does that impact approval if applicant properly answers requirements asked for elsewhere in the application? - D.4 - Registration volume. How would that impact the approval of the accreditation? - D.6/D.7 - Both seem to ask the same thing? Consolidate or refine? - D.8 - Staffing - Maybe something that can be grouped near registrar operations questions. If applicant is affiliated with a registrar, I do not think it will be easy to call out how much staff specifically will be involved with this part of operations. Regards, Eric On Wed, May 24, 2017 at 1:43 PM, Metalitz, Steven <met@msk.com> wrote:
Thanks for preparing these additional documents, Amy.
One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant’s standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a “business registration certificate” as a “required appendix” –so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in “documentation demonstrating that the Applicant entity is legally established and in good standing”, to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities?
I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline.
*[image: image001]*
*Steven J. Metalitz *| *Partner, through his professional corporation*
T: 202.355.7902 <(202)%20355-7902> | met@msk.com
*Mitchell Silberberg & Knupp* *LLP* | *www.msk.com <http://www.msk.com/>*
1818 N Street NW, 8th Floor, Washington, DC 20036
*THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS.** THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.*
*From:* gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl- bounces@icann.org] *On Behalf Of *Amy Bivins *Sent:* Tuesday, May 23, 2017 12:13 PM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
Dear Colleagues,
This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week.
Best, Amy
Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week’s meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don’t hesitate to reply to the list or contact me directly.
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 <(202)%20249-7551> Fax: +1 (202) 789-0104 <(202)%20789-0104> Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ 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
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- *Eric Rokobauer* Senior Manager, Registrar Compliance +1-602-226-2372 <602-226-2372>
Thanks, Eric! I will add these to the list of topics to discuss on Tuesday. Where questions are re-ordered/combined from the registrar accreditation application, we were attempting to reduce the number of questions in this draft application where questions seemed like they could be answered together. But if the group finds that confusing, we don’t have to take that approach. This is exactly the kind of feedback we are seeking here, so I hope others on the IRT have the opportunity to think about these documents this week. Best, Amy From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Eric Rokobauer Sent: Thursday, May 25, 2017 2:00 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thank you Amy for providing the documentation for review. Please find some remarks and thoughts on the questions presented. Referencing the comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation. * Why is some of the draft P/P application reorganized from what is used for registrars? For instance, line 2 has legal for form of applicant for registrars, but that seems to be missing for P/P providers. Not sure of the reason for these differences. * A.1 for the P/P draft has a note stating "combination of Rr APP Qs 1 and 4". What was the reasoning there? * Regarding line 5 - do we not intend to ask for documentation of good standing for P/P providers the way we do for registrars? Was it not the PPSAI PDP WG intention to hold the P/P providers to the same accreditation standards as registrars? * Leading into comments below, might work to start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline. Referencing the annotated version of the draft v1 application for privacy/proxy service provider accreditation. * 12 months makes sense for a timeline. I remember one comment came up during our last call inquiring if ICANN would take applications before month 3 when application window starts. Any update there? * Is there interest in reducing the application window itself (between month 3 and 6)? Less time to apply, but quicker turnaround for all? Interested for thoughts here from IRT. As you are reviewing these documents, please consider the following questions: (a) Is this proposed process consistent with the intent of the Policy recommendations? Yes, but the misalignment of requirements (line by line) between the current registrar application and the p/p draft makes this difficult to compare the two. Can we realign or display in a different manner? (c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? This was something I had called out in our last call. Certain questions specifically associated to registrar operations (data escrow, registrant validation/verification) should be sectioned together. If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided. (d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? Yes. Unaffiliated P/P providers need to complete the full application with all requirements for operation answered. (e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? Yes. Primarily those that looked to have been designed for registrar operations. Details that P/P provider applicants may not necessarily be privy to. * D.2 - Length of time already providing service. How does that impact approval if applicant properly answers requirements asked for elsewhere in the application? * D.4 - Registration volume. How would that impact the approval of the accreditation? * D.6/D.7 - Both seem to ask the same thing? Consolidate or refine? * D.8 - Staffing - Maybe something that can be grouped near registrar operations questions. If applicant is affiliated with a registrar, I do not think it will be easy to call out how much staff specifically will be involved with this part of operations. Regards, Eric On Wed, May 24, 2017 at 1:43 PM, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: Thanks for preparing these additional documents, Amy. One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant’s standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a “business registration certificate” as a “required appendix” –so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in “documentation demonstrating that the Applicant entity is legally established and in good standing”, to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities? I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902<tel:(202)%20355-7902> | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Amy Bivins Sent: Tuesday, May 23, 2017 12:13 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week’s meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don’t hesitate to reply to the list or contact me directly.
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<tel:(202)%20249-7551> Fax: +1 (202) 789-0104<tel:(202)%20789-0104> Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org<mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org>> www.icann.org<http://www.icann.org><http://www.icann.org>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto: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<mailto: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<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Eric Rokobauer Senior Manager, Registrar Compliance +1-602-226-2372<tel:602-226-2372> [http://www.enduranceinternational.com/img/nav/logo_retina.gif]
I won’t be able to make the call Tuesday, but I’d like to second Eric’s comments on two points: Regarding the annotated application: * start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline. · If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided. There should be some type of mechanism to confirm things like “same address as registrar” without having to fill out these fields all over again. An option for registrars to have their registrar information populated and simply change any fields that are different would be great. Regarding the reduction of requirements, I agree that Eric’s examples are not necessary for the p/p provider application. From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, May 25, 2017 6:25 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thanks, Eric! I will add these to the list of topics to discuss on Tuesday. Where questions are re-ordered/combined from the registrar accreditation application, we were attempting to reduce the number of questions in this draft application where questions seemed like they could be answered together. But if the group finds that confusing, we don’t have to take that approach. This is exactly the kind of feedback we are seeking here, so I hope others on the IRT have the opportunity to think about these documents this week. Best, Amy From: gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Eric Rokobauer Sent: Thursday, May 25, 2017 2:00 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thank you Amy for providing the documentation for review. Please find some remarks and thoughts on the questions presented. Referencing the comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation. * Why is some of the draft P/P application reorganized from what is used for registrars? For instance, line 2 has legal for form of applicant for registrars, but that seems to be missing for P/P providers. Not sure of the reason for these differences. * A.1 for the P/P draft has a note stating "combination of Rr APP Qs 1 and 4". What was the reasoning there? * Regarding line 5 - do we not intend to ask for documentation of good standing for P/P providers the way we do for registrars? Was it not the PPSAI PDP WG intention to hold the P/P providers to the same accreditation standards as registrars? * Leading into comments below, might work to start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline. Referencing the annotated version of the draft v1 application for privacy/proxy service provider accreditation. * 12 months makes sense for a timeline. I remember one comment came up during our last call inquiring if ICANN would take applications before month 3 when application window starts. Any update there? * Is there interest in reducing the application window itself (between month 3 and 6)? Less time to apply, but quicker turnaround for all? Interested for thoughts here from IRT. As you are reviewing these documents, please consider the following questions: (a) Is this proposed process consistent with the intent of the Policy recommendations? Yes, but the misalignment of requirements (line by line) between the current registrar application and the p/p draft makes this difficult to compare the two. Can we realign or display in a different manner? (c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? This was something I had called out in our last call. Certain questions specifically associated to registrar operations (data escrow, registrant validation/verification) should be sectioned together. If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided. (d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? Yes. Unaffiliated P/P providers need to complete the full application with all requirements for operation answered. (e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? Yes. Primarily those that looked to have been designed for registrar operations. Details that P/P provider applicants may not necessarily be privy to. * D.2 - Length of time already providing service. How does that impact approval if applicant properly answers requirements asked for elsewhere in the application? * D.4 - Registration volume. How would that impact the approval of the accreditation? * D.6/D.7 - Both seem to ask the same thing? Consolidate or refine? * D.8 - Staffing - Maybe something that can be grouped near registrar operations questions. If applicant is affiliated with a registrar, I do not think it will be easy to call out how much staff specifically will be involved with this part of operations. Regards, Eric On Wed, May 24, 2017 at 1:43 PM, Metalitz, Steven <met@msk.com<mailto:met@msk.com>> wrote: Thanks for preparing these additional documents, Amy. One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant’s standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a “business registration certificate” as a “required appendix” –so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in “documentation demonstrating that the Applicant entity is legally established and in good standing”, to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities? I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902<tel:(202)%20355-7902> | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Amy Bivins Sent: Tuesday, May 23, 2017 12:13 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week’s meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don’t hesitate to reply to the list or contact me directly.
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<tel:(202)%20249-7551> Fax: +1 (202) 789-0104<tel:(202)%20789-0104> Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org<mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org>> www.icann.org<http://www.icann.org><http://www.icann.org>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto: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<mailto: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<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Eric Rokobauer Senior Manager, Registrar Compliance +1-602-226-2372<tel:602-226-2372> [http://www.enduranceinternational.com/img/nav/logo_retina.gif]
Thanks Greg, I would caution, we should remind ourselves of the definition of Affiliated with a Registrar from the 2013 RAA: 1.3 "Affiliate" means a person or entity that, directly or indirectly, through one or more intermediaries, Controls, is controlled by, or is under common control with, the person or entity specified. 1.4 "Affiliated Registrar" is another Accredited registrar that is an Affiliate of Registrar. I don’t think it requires common address, personnel, or even technical infrastructure. For clarification, are you suggesting we refer back to the registrar application to determine an applicant for a P/P service is technically or operationally qualified or just to verify they are a currently accredited registrar in good standing? Thanks, Russ Director, Global Implementation ICANN From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of DiBiase, Gregory via Gdd-gnso-ppsai-impl Sent: Thursday, May 25, 2017 10:13 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time I won’t be able to make the call Tuesday, but I’d like to second Eric’s comments on two points: Regarding the annotated application: * start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline. * If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided. There should be some type of mechanism to confirm things like “same address as registrar” without having to fill out these fields all over again. An option for registrars to have their registrar information populated and simply change any fields that are different would be great. Regarding the reduction of requirements, I agree that Eric’s examples are not necessary for the p/p provider application. From: gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Thursday, May 25, 2017 6:25 AM To: gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thanks, Eric! I will add these to the list of topics to discuss on Tuesday. Where questions are re-ordered/combined from the registrar accreditation application, we were attempting to reduce the number of questions in this draft application where questions seemed like they could be answered together. But if the group finds that confusing, we don’t have to take that approach. This is exactly the kind of feedback we are seeking here, so I hope others on the IRT have the opportunity to think about these documents this week. Best, Amy From: gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Eric Rokobauer Sent: Thursday, May 25, 2017 2:00 AM To: gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thank you Amy for providing the documentation for review. Please find some remarks and thoughts on the questions presented. Referencing the comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation. * Why is some of the draft P/P application reorganized from what is used for registrars? For instance, line 2 has legal for form of applicant for registrars, but that seems to be missing for P/P providers. Not sure of the reason for these differences. * A.1 for the P/P draft has a note stating "combination of Rr APP Qs 1 and 4". What was the reasoning there? * Regarding line 5 - do we not intend to ask for documentation of good standing for P/P providers the way we do for registrars? Was it not the PPSAI PDP WG intention to hold the P/P providers to the same accreditation standards as registrars? * Leading into comments below, might work to start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline. Referencing the annotated version of the draft v1 application for privacy/proxy service provider accreditation. * 12 months makes sense for a timeline. I remember one comment came up during our last call inquiring if ICANN would take applications before month 3 when application window starts. Any update there? * Is there interest in reducing the application window itself (between month 3 and 6)? Less time to apply, but quicker turnaround for all? Interested for thoughts here from IRT. As you are reviewing these documents, please consider the following questions: (a) Is this proposed process consistent with the intent of the Policy recommendations? Yes, but the misalignment of requirements (line by line) between the current registrar application and the p/p draft makes this difficult to compare the two. Can we realign or display in a different manner? (c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? This was something I had called out in our last call. Certain questions specifically associated to registrar operations (data escrow, registrant validation/verification) should be sectioned together. If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided. (d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? Yes. Unaffiliated P/P providers need to complete the full application with all requirements for operation answered. (e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? Yes. Primarily those that looked to have been designed for registrar operations. Details that P/P provider applicants may not necessarily be privy to. * D.2 - Length of time already providing service. How does that impact approval if applicant properly answers requirements asked for elsewhere in the application? * D.4 - Registration volume. How would that impact the approval of the accreditation? * D.6/D.7 - Both seem to ask the same thing? Consolidate or refine? * D.8 - Staffing - Maybe something that can be grouped near registrar operations questions. If applicant is affiliated with a registrar, I do not think it will be easy to call out how much staff specifically will be involved with this part of operations. Regards, Eric On Wed, May 24, 2017 at 1:43 PM, Metalitz, Steven <met@msk.com <mailto:met@msk.com> > wrote: Thanks for preparing these additional documents, Amy. One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant’s standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a “business registration certificate” as a “required appendix” –so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in “documentation demonstrating that the Applicant entity is legally established and in good standing”, to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities? I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline. Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 <tel:(202)%20355-7902> | <mailto:met@msk.com> met@msk.com Mitchell Silberberg & Knupp LLP | <http://www.msk.com/> www.msk.com 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> ] On Behalf Of Amy Bivins Sent: Tuesday, May 23, 2017 12:13 PM To: gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org> > wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week’s meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don’t hesitate to reply to the list or contact me directly.
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 <tel:(202)%20249-7551> Fax: +1 (202) 789-0104 <tel:(202)%20789-0104> Email: amy.bivins@icann.org <mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org> <mailto:amy.bivins@icann.org> www.icann.org <http://www.icann.org> <http://www.icann.org>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org <mailto: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 <mailto: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 <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Eric Rokobauer Senior Manager, Registrar Compliance +1-602-226-2372 <tel:602-226-2372> <http://www.enduranceinternational.com/img/nav/logo_retina.gif>
I agree with Eric and Greg. Theo On 25-5-2017 19:12, DiBiase, Gregory via Gdd-gnso-ppsai-impl wrote:
I won’t be able to make the call Tuesday, but I’d like to second Eric’s comments on two points:
Regarding the annotated application:
* start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline.
·If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided.
There should be some type of mechanism to confirm things like “same address as registrar” without having to fill out these fields all over again. An option for registrars to have their registrar information populated and simply change any fields that are different would be great.
Regarding the reduction of requirements, I agree that Eric’s examples are not necessary for the p/p provider application.
*From:*gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Amy Bivins *Sent:* Thursday, May 25, 2017 6:25 AM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
Thanks, Eric!
I will add these to the list of topics to discuss on Tuesday. Where questions are re-ordered/combined from the registrar accreditation application, we were attempting to reduce the number of questions in this draft application where questions seemed like they could be answered together. But if the group finds that confusing, we don’t have to take that approach.
This is exactly the kind of feedback we are seeking here, so I hope others on the IRT have the opportunity to think about these documents this week.
Best,
Amy
*From:*gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Eric Rokobauer *Sent:* Thursday, May 25, 2017 2:00 AM *To:* gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
Thank you Amy for providing the documentation for review. Please find some remarks and thoughts on the questions presented.
/Referencing the comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation./
* Why is some of the draft P/P application reorganized from what is used for registrars? For instance, line 2 has legal for form of applicant for registrars, but that seems to be missing for P/P providers. Not sure of the reason for these differences. * A.1 for the P/P draft has a note stating "combination of Rr APP Qs 1 and 4". What was the reasoning there? * Regarding line 5 - do we not intend to ask for documentation of good standing for P/P providers the way we do for registrars? Was it not the PPSAI PDP WG intention to hold the P/P providers to the same accreditation standards as registrars? * Leading into comments below, might work to start off the application with “Are you affiliated with an ICANN-accredited registrar?” for clarity and to help streamline.
/Referencing the annotated version of the draft v1 application for privacy/proxy service provider accreditation./
* 12 months makes sense for a timeline. I remember one comment came up during our last call inquiring if ICANN would take applications before month 3 when application window starts. Any update there? * Is there interest in reducing the application window itself (between month 3 and 6)? Less time to apply, but quicker turnaround for all? Interested for thoughts here from IRT.
/As you are reviewing these documents, please consider the following questions:/
/(a)////Is this proposed process consistent with the intent of the Policy recommendations?/
Yes, but the misalignment of requirements (line by line) between the current registrar application and the p/p draft makes this difficult to compare the two. Can we realign or display in a different manner?
/(c)////Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?/
This was something I had called out in our last call. Certain questions specifically associated to registrar operations (data escrow, registrant validation/verification) should be sectioned together. If applicant states to be affiliated with a registrar, ICANN will be able to quickly take that said group of answers and cross check with what should already be available from the accredited registrar provided.
/(d)////Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?/
Yes. Unaffiliated P/P providers need to complete the full application with all requirements for operation answered.
/(e)////Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?/
Yes. Primarily those that looked to have been designed for registrar operations. Details that P/P provider applicants may not necessarily be privy to.
* D.2 - Length of time already providing service. How does that impact approval if applicant properly answers requirements asked for elsewhere in the application? * D.4 - Registration volume. How would that impact the approval of the accreditation? * D.6/D.7 - Both seem to ask the same thing? Consolidate or refine? * D.8 - Staffing - Maybe something that can be grouped near registrar operations questions. If applicant is affiliated with a registrar, I do not think it will be easy to call out how much staff specifically will be involved with this part of operations.
Regards,
Eric
On Wed, May 24, 2017 at 1:43 PM, Metalitz, Steven <met@msk.com <mailto:met@msk.com>> wrote:
Thanks for preparing these additional documents, Amy.
One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant’s standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a “business registration certificate” as a “required appendix” –so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in “documentation demonstrating that the Applicant entity is legally established and in good standing”, to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities?
I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline.
*image001*
*Steven J. Metalitz *|***Partner, through his professional corporation*
T: 202.355.7902 <tel:%28202%29%20355-7902> | met@msk.com <mailto:met@msk.com>
*Mitchell Silberberg & Knupp**LLP*|*www.msk.com <http://www.msk.com/>*
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*_THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS._**THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.*
*From:*gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org <mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] *On Behalf Of *Amy Bivins *Sent:* Tuesday, May 23, 2017 12:13 PM *To:* gdd-gnso-ppsai-impl@icann.org <mailto:gdd-gnso-ppsai-impl@icann.org> *Subject:* Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time
Dear Colleagues,
This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week.
Best, Amy
Sent from my iPhone
> On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org <mailto:amy.bivins@icann.org>> wrote: > > Dear Colleagues, > > Thanks so much for your active participation on yesterday’s Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017 > > As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide: > > (1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached). > > (2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report. > > > As you are reviewing these documents, please consider the following questions: > > (a) Is this proposed process consistent with the intent of the Policy recommendations? > > (b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations? > > (c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers? > > (d) Are there processes/criteria that may require “implementation adjustment” (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars? > > (e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner? > > > > Next week’s meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May. > > > > If you have questions or comments between now and then, please don’t hesitate to reply to the list or contact me directly. > > > > 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 <tel:%28202%29%20249-7551> > Fax: +1 (202) 789-0104 <tel:%28202%29%20789-0104> > Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org <mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org>> > www.icann.org <http://www.icann.org><http://www.icann.org> > > > > <PP_App_Guide_IRTv1.pdf> > <Rr_PP_App_Comparison.pdf> > <PP_App_Draftv1_Annotated.pdf> > _______________________________________________ > Gdd-gnso-ppsai-impl mailing list > Gdd-gnso-ppsai-impl@icann.org <mailto: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 <mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
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Senior Manager, Registrar Compliance
+1-602-226-2372 <tel:602-226-2372>
* *
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Thanks so much for this feedback, Steve. I'll add this to the list of items to discuss on Tuesday. In the draft application, we eliminated that question thinking that the documentation requirement at the end could replace it-will make a note to clarify the documentation requirement in the next draft. 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> From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Metalitz, Steven Sent: Wednesday, May 24, 2017 4:44 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Thanks for preparing these additional documents, Amy. One fairly small point: the draft P/P accreditation application omits questions regarding proof of the applicant's standing to do business in the jurisdiction in which it claims to be domiciled. By comparison, question 3 and 5 of the registrar application ask for this information. I note that the P/P application asks for a "business registration certificate" as a "required appendix" -so maybe #3 is covered (though perhaps it should be clarified just what the applicant is required to submit, i.e., a current certificate issued by the jurisdiction in which domicile is claimed). But is there a reason applicant would not be required to show that what it asserts to be its form of business organization is in fact reflected in "documentation demonstrating that the Applicant entity is legally established and in good standing", to quote Q.5 of the registrar application? Because in some circumstances the provider could designate the jurisdiction in which it is organized as the venue for resolving disputes, wouldn't it be important to document that it is in fact organized there, that it is subject to service of process there, and that it is in good standing in the eyes of the courts or other relevant authorities? I may have other questions to raise as I continue to go through these documents but thought I would not wait to accumulate them, in order to meet your requested deadline. [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, May 23, 2017 12:13 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] Materials for PP IRT Review, Meeting Next Week Canceled to Provide Additional Review Time Dear Colleagues, This is a reminder that we are seeking your feedback on the documents referenced below no later than Thursday 25 May. Your feedback on these will likely be the bulk of our agenda for next week. Best, Amy Sent from my iPhone
On May 17, 2017, at 2:13 PM, Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote:
Dear Colleagues,
Thanks so much for your active participation on yesterday's Privacy/Proxy IRT call. The meeting recording and materials are available on the wiki: https://community.icann.org/display/IRT/16+May+2017
As a reminder, we are requesting your feedback on the draft v1 applicant guide, distributed to the IRT last week and also attached. Following our discussion yesterday, I created two new documents to aid your review of the draft applicant guide:
(1) a comparison document that shows the differences between the current ICANN application for registrar accreditation and the draft v1 application for privacy/proxy service provider accreditation (attached).
(2) An annotated version of the draft v1 application for privacy/proxy service provider accreditation (attached), noting questions that are proposed in response to a specific recommendation from the Final Report.
As you are reviewing these documents, please consider the following questions:
(a) Is this proposed process consistent with the intent of the Policy recommendations?
(b) Do the proposed evaluation criteria seem to be consistent with the intent of the Policy recommendations?
(c) Are there areas where ICANN should consider streamlining the evaluation for registrar-Affiliated providers?
(d) Are there processes/criteria that may require "implementation adjustment" (as noted in p. 6 of the Final Report) in the case of providers that are not affiliated with ICANN-accredited registrars?
(e) Should ICANN consider reducing the number of evaluation questions and instead ensure that the applicant understands and agrees to comply with the relevant requirements via the required applicant educational program (and screening test, as discussed in April?). If so, which questions do you believe could/should be evaluated in this manner?
Next week's meeting, scheduled for 23 May, is canceled to provide additional time for this review. Our next meeting will be on 30 May 2017. Please send your feedback on these documents to the list no later than your EOD 25 May.
If you have questions or comments between now and then, please don't hesitate to reply to the list or contact me directly.
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<mailto:amy.bivins@icann.org%3cmailto:amy.bivins@icann.org>> www.icann.org<http://www.icann.org><http://www.icann.org>
<PP_App_Guide_IRTv1.pdf> <Rr_PP_App_Comparison.pdf> <PP_App_Draftv1_Annotated.pdf> _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org<mailto: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<mailto:Gdd-gnso-ppsai-impl@icann.org> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
participants (6)
-
Amy Bivins -
DiBiase, Gregory -
Eric Rokobauer -
Metalitz, Steven -
Russ Weinstein -
theo geurts