Agreed, if the provider is awol, then we should not expect much from them. Section 3.3.5 Without going into the operational challenges we might/should make sure this section allows Registrars a lot of flexibility here. I cautioned about the GDPR data breach possibility, most likely ICANN as the data controller will be liable here, but we should come up with something that makes sure this does not happen. This might be a sub team task. 3.5 A privacy service is a service, not a domain name. Under the current language, a customer can choose between privacy providers without transferring the actual domain name. The same logic applies when it comes to de-accreditation. Section 5. I am not going to belabor this point. This procedure deals with domain names, where a Registrar gets domain names transferred to its accreditation. What is happening is that a domain name registrant contact gets updated.  An update to the WHOIS records at best. 5.4  Good to notice that ICANN will do all the work here. To make this work detailed Escrow data for nonaffiliated providers is key here. De-Accredited Registrar Transition Procedure in general. Tom Barret pointed out that this is in some cases, call it doing the community a favor here. You might get 1000 domain names on your accreditation really easy if you get some renewals out of it, great, you made some money as a Registrar, though most likely you did a ton of work and got paid peanuts in the end. But that is a business decision or better put, you doing ICANN a favor and its community and the registrants. What I the privacy provider is offering the privacy service for free? As the gaining privacy provider and you charge money you know for sure that those customers are not going to renew, they want out to another privacy provider that offers the service for free. If if the gaining privacy provider does provide the service for free then this provider will do a ton of work for nothing, there is nothing to gain except liability issues. In fact, you have to verify, suspend domain names and your support staff will go nuclear and not having a good week. 6 I expect there will be no pool of privacy providers. I have looked at the DART program a few years back; I truly appreciate what Tom Barret and other Registrars in that pool are doing. But the reality it is an amazing boatload of work. Sometimes the data quality is poor and requires a lot of scripting. Best regards, Theo Geurts On 4-9-2017 12:57, Michele Neylon - Blacknight wrote:

Amy et al

Just browsing this quickly and I can see some serious gaps

If ICANN is suspending a provider it’s due to any number of issues so relying on the same provider you’re suspending to send notices to anyone is simply not going to work.

You’re probably suspending them for breaching the policies / contract etc., so I can’t imagine they’d be likely to start sending out notices at this juncture.

All of the language around customer notification is linked to the provider co-operating and acting and to be frank I can’t see that happening in a lot of cases.

Regards

Michele

--

Mr Michele Neylon

Blacknight Solutions

Hosting, Colocation & Domains

https://www.blacknight.com/

http://blacknight.blog/

Intl. +353 (0) 59  9183072

Direct Dial: +353 (0)59 9183090

Personal blog: https://michele.blog/

Some thoughts: https://ceo.hosting/

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Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845

*From: *<gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Date: *Friday 1 September 2017 at 15:46 *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *[Gdd-gnso-ppsai-impl] Materials, Agenda for 5 Sept PP IRT Meeting

Hello, All,

Attached is the first IRT discussion draft of the privacy/proxy provider suspension and de-accreditation procedure, which we will be discussing during Tuesday’s IRT meeting. Please review this document prior to our meeting on Tuesday.

In addition, we plan to discuss the issue raised on-list by Sara Bockey, regarding the draft PPAA’s requirement for 24/7/365 monitoring of a provider’s abuse contact (modeled on the RAA). We are also planning to discuss next steps on data retention.

As a reminder, please send any additional feedback you have regarding the issues discussed during Tuesday’s meeting to the list this week.

Thanks, and have a great weekend.

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>

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