Materials, action items from 3 October Privacy/Proxy IRT call
Dear Colleagues, Thank you for your participation on the last Privacy/Proxy IRT call on Tuesday, 3 October. For those who could not attend, I encourage you to review the recording (https://participate.icann.org/p8dnkiub56v/) and materials on the wiki, https://community.icann.org/display/IRT/03+October+2017. I attached two documents for your review: The updated Applicant Guidebook/Application (v3) The updated De-Accreditation Procedure (v2) Notes on Updated Applicant Guide We received feedback from the IRT that the application process should be simplified, which included (1) consolidation of “tracks”, i.e., rather than four tracks, there should be two tracks: unaffiliated entities and affiliated entities; (2) a streamlined application, which includes only necessary long-form/essay questions and a “check box”, short form for the majority of questions. Further to that feedback, please review the next iteration (v3) of the Applicant Guidebook, with particular attention to Sections 5-6 (p. 10-11). Please provide any additional feedback to the list by Tuesday, 10 October. We will discuss any updates on our call next Tuesday. Notes on De-Accreditation Procedure Further to your feedback on the last call about de-accreditation, we removed the text in section 2.4.6 about a customer’s personal information being revealed in WHOIS following a termination of a P/P Provider to reflect the reality of a termination, which would involve a potential suspension (per the Whois Accuracy Program Specification (WAPS) as opposed to publication of underlying customer information in RDDS. A few members of the IRT expressed concern with treating the information as inaccurate and suspending names after 15 days, per the WAPS. We proposed to change that period to 30 days, i.e., following a termination of a P/P provider, the gaining provider/registrar would have 30 days to contact the customers to correct the inaccurate WHOIS information before potential suspension. Additionally, a member of the IRT expressed a concern as to which entity (the terminated or gaining provider) would be in charge of processing abuse complaints during terminations. Until the date of P/P provider is terminated, the terminating provider would be responsible for handling abuse tickets, as that entity would still be under contract. Following the termination date, the new provider would be responsible for processing abuse complaints. A member of the IRT noted a potential gap, where an individual/entity may file a complaint with the terminating entity, but if it is not responded to, it would need to file a new version of the same complaint with the gaining entity. If you have any suggestions about how this should be handled, please feel free to make suggestions to the list by Tuesday, 10 October. On our next call on Tuesday, 10 October, we will be discussing the proposed updates to the attached documents. I am also hoping to have the next iteration of the Accreditaiton Agreement to share with you early next week. Thank you again for all of your work on this! Best regards, Caitlin
Hi Caitlin, Some initial comments on the revised Applicant Guide: 1. The two track system is a big improvement. Much clearer. 2. I noticed the fees have been removed. Will new fees be proposed for next week’s meeting? I also believe ICANN was going to provide actual costs for background checks (the rationale for application fees), when will those be provided? 3. Re Section 3.2, why is the applicant providing information on when ICANN last performed a background check on the applicant’s affiliated entity? Doesn’t ICANN know this? I would like to reiterate Volker’s position that background checks should not be required for affiliated entities. If a check has already been conducted on an affiliated entity, responses to the questions in the rest of section 3 should be sufficient. 4. Re 5.2: I lost track of where we are on identifying that the registration is a privacy/proxy registration, but wasn’t this concern already accounted for in the rules generally? I don’t think it should solved by providers individually and therefore this question is not necessary. 5. Generally, the change from asking for descriptions to asking for confirmation is welcome. From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Caitlin Tubergen Sent: Wednesday, October 04, 2017 6:36 PM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] Materials, action items from 3 October Privacy/Proxy IRT call Dear Colleagues, Thank you for your participation on the last Privacy/Proxy IRT call on Tuesday, 3 October. For those who could not attend, I encourage you to review the recording (https://participate.icann.org/p8dnkiub56v/<https://participate.icann.org/p8dnkiub56v/?OWASP_CSRFTOKEN=ebda0b0ecee56f6650584ca3c6df298c9b9b9d14eecf0b0d980f2dd84f7c45cb>) and materials on the wiki, https://community.icann.org/display/IRT/03+October+2017. I attached two documents for your review: (1) The updated Applicant Guidebook/Application (v3) (2) The updated De-Accreditation Procedure (v2) Notes on Updated Applicant Guide We received feedback from the IRT that the application process should be simplified, which included (1) consolidation of “tracks”, i.e., rather than four tracks, there should be two tracks: unaffiliated entities and affiliated entities; (2) a streamlined application, which includes only necessary long-form/essay questions and a “check box”, short form for the majority of questions. Further to that feedback, please review the next iteration (v3) of the Applicant Guidebook, with particular attention to Sections 5-6 (p. 10-11). Please provide any additional feedback to the list by Tuesday, 10 October. We will discuss any updates on our call next Tuesday. Notes on De-Accreditation Procedure Further to your feedback on the last call about de-accreditation, we removed the text in section 2.4.6 about a customer’s personal information being revealed in WHOIS following a termination of a P/P Provider to reflect the reality of a termination, which would involve a potential suspension (per the Whois Accuracy Program Specification (WAPS) as opposed to publication of underlying customer information in RDDS. A few members of the IRT expressed concern with treating the information as inaccurate and suspending names after 15 days, per the WAPS. We proposed to change that period to 30 days, i.e., following a termination of a P/P provider, the gaining provider/registrar would have 30 days to contact the customers to correct the inaccurate WHOIS information before potential suspension. Additionally, a member of the IRT expressed a concern as to which entity (the terminated or gaining provider) would be in charge of processing abuse complaints during terminations. Until the date of P/P provider is terminated, the terminating provider would be responsible for handling abuse tickets, as that entity would still be under contract. Following the termination date, the new provider would be responsible for processing abuse complaints. A member of the IRT noted a potential gap, where an individual/entity may file a complaint with the terminating entity, but if it is not responded to, it would need to file a new version of the same complaint with the gaining entity. If you have any suggestions about how this should be handled, please feel free to make suggestions to the list by Tuesday, 10 October. On our next call on Tuesday, 10 October, we will be discussing the proposed updates to the attached documents. I am also hoping to have the next iteration of the Accreditaiton Agreement to share with you early next week. Thank you again for all of your work on this! Best regards, Caitlin
Thanks, Caitlin, this looks pretty good. On the PPSAI applicant guide Section 3 The significant changes proposed by one IRT member did not receive full support. I missed the last call and still catching up, but if this these are the edits, Volker proposed a few weeks back they have my full support. As they were discussed with several other Registrar IRT members, I would even argue the lack of support means full support, but if there are Registrars on the list who feel the proposed edit by Volker do not meet their support, perhaps they should mention this on the list or the call. Section 3.2 I agree with Volkers position as mentioned by Greg. Sections 3.3-3.15 I think we are out of scope here. This looks more like the IRT is going to change the RAA 2013 requirements. The language in the RAA 2013 should not be exceeded by the PPSAI IRT unless specified by the WG recommendations. Afterall when this policy goes into effect, these sections will replace the ones within the RAA 2013. 6.4 This is problematic for Wholesale Registrars as the customers are not the customers of the Registrars but rather of their resellers. 6.5 Make this a pending item? We still need to figure out if the enabling or disabling of privacy services or the termination as such is part of IRTP-C. 6.10 I am somewhat struggling with this section, it seems to have a specific goal in mind but the current draft somehow overshoots the goal. A TOS is not something static and may change and be different from what was submitted during the application. Best, Theo Geurts DiBiase, Gregory via Gdd-gnso-ppsai-impl schreef op 2017-10-08 09:41 PM:
Hi Caitlin,
Some initial comments on the revised Applicant Guide:
1. The two track system is a big improvement. Much clearer.
2. I noticed the fees have been removed. Will new fees be proposed for next week’s meeting? I also believe ICANN was going to provide actual costs for background checks (the rationale for application fees), when will those be provided?
3. Re Section 3.2, why is the applicant providing information on when ICANN last performed a background check on the applicant’s affiliated entity? Doesn’t ICANN know this? I would like to reiterate Volker’s position that background checks should not be required for affiliated entities. If a check has already been conducted on an affiliated entity, responses to the questions in the rest of section 3 should be sufficient.
4. Re 5.2: I lost track of where we are on identifying that the registration is a privacy/proxy registration, but wasn’t this concern already accounted for in the rules generally? I don’t think it should solved by providers individually and therefore this question is not necessary.
5. Generally, the change from asking for descriptions to asking for confirmation is welcome.
FROM: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] ON BEHALF OF Caitlin Tubergen SENT: Wednesday, October 04, 2017 6:36 PM TO: gdd-gnso-ppsai-impl@icann.org SUBJECT: [Gdd-gnso-ppsai-impl] Materials, action items from 3 October Privacy/Proxy IRT call
Dear Colleagues,
Thank you for your participation on the last Privacy/Proxy IRT call on Tuesday, 3 October. For those who could not attend, I encourage you to review the recording (HTTPS://PARTICIPATE.ICANN.ORG/P8DNKIUB56V/ [1]) and materials on the wiki, https://community.icann.org/display/IRT/03+October+2017 [2].
I attached two documents for your review:
(1) The updated Applicant Guidebook/Application (v3)
(2) The updated De-Accreditation Procedure (v2)
NOTES ON UPDATED APPLICANT GUIDE
We received feedback from the IRT that the application process should be simplified, which included (1) consolidation of “tracks”, i.e., rather than four tracks, there should be two tracks: unaffiliated entities and affiliated entities; (2) a streamlined application, which includes only necessary long-form/essay questions and a “check box”, short form for the majority of questions. Further to that feedback, please review the next iteration (v3) of the Applicant Guidebook, with particular attention to Sections 5-6 (p. 10-11). Please provide any additional feedback to the list by TUESDAY, 10 OCTOBER. We will discuss any updates on our call next Tuesday.
NOTES ON DE-ACCREDITATION PROCEDURE
Further to your feedback on the last call about de-accreditation, we removed the text in section 2.4.6 about a customer’s personal information being revealed in WHOIS following a termination of a P/P Provider to reflect the reality of a termination, which would involve a potential suspension (per the Whois Accuracy Program Specification (WAPS) as opposed to publication of underlying customer information in RDDS. A few members of the IRT expressed concern with treating the information as inaccurate and suspending names after 15 days, per the WAPS. We proposed to change that period to 30 DAYS, i.e., following a termination of a P/P provider, the gaining provider/registrar would have 30 days to contact the customers to correct the inaccurate WHOIS information before potential suspension.
Additionally, a member of the IRT expressed a concern as to which entity (the terminated or gaining provider) would be in charge of processing abuse complaints during terminations. Until the date of P/P provider is terminated, the terminating provider would be responsible for handling abuse tickets, as that entity would still be under contract. Following the termination date, the new provider would be responsible for processing abuse complaints. A member of the IRT noted a potential gap, where an individual/entity may file a complaint with the terminating entity, but if it is not responded to, it would need to file a new version of the same complaint with the gaining entity. If you have any suggestions about how this should be handled, please feel free to make suggestions to the list by TUESDAY, 10 OCTOBER.
On our next call on Tuesday, 10 October, we will be discussing the proposed updates to the attached documents. I am also hoping to have the next iteration of the Accreditaiton Agreement to share with you early next week.
Thank you again for all of your work on this!
Best regards,
Caitlin
Links: ------ [1] https://participate.icann.org/p8dnkiub56v/?OWASP_CSRFTOKEN=ebda0b0ecee56f665... [2] https://community.icann.org/display/IRT/03+October+2017 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Why has the word “specific” been deleted from section 6.10 of the Applicant Guide v.3? The WG consensus recommendations (#8) called for the specific grounds for disclosure, publication, and service termination to be disclosed in the published TOS. [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 gtheo Sent: Monday, October 09, 2017 6:38 AM To: DiBiase, Gregory; gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] Materials, action items from 3 October Privacy/Proxy IRT call Thanks, Caitlin, this looks pretty good. On the PPSAI applicant guide Section 3 The significant changes proposed by one IRT member did not receive full support. I missed the last call and still catching up, but if this these are the edits, Volker proposed a few weeks back they have my full support. As they were discussed with several other Registrar IRT members, I would even argue the lack of support means full support, but if there are Registrars on the list who feel the proposed edit by Volker do not meet their support, perhaps they should mention this on the list or the call. Section 3.2 I agree with Volkers position as mentioned by Greg. Sections 3.3-3.15 I think we are out of scope here. This looks more like the IRT is going to change the RAA 2013 requirements. The language in the RAA 2013 should not be exceeded by the PPSAI IRT unless specified by the WG recommendations. Afterall when this policy goes into effect, these sections will replace the ones within the RAA 2013. 6.4 This is problematic for Wholesale Registrars as the customers are not the customers of the Registrars but rather of their resellers. 6.5 Make this a pending item? We still need to figure out if the enabling or disabling of privacy services or the termination as such is part of IRTP-C. 6.10 I am somewhat struggling with this section, it seems to have a specific goal in mind but the current draft somehow overshoots the goal. A TOS is not something static and may change and be different from what was submitted during the application. Best, Theo Geurts DiBiase, Gregory via Gdd-gnso-ppsai-impl schreef op 2017-10-08 09:41 PM:
Hi Caitlin,
Some initial comments on the revised Applicant Guide:
1. The two track system is a big improvement. Much clearer.
2. I noticed the fees have been removed. Will new fees be proposed for next week’s meeting? I also believe ICANN was going to provide actual costs for background checks (the rationale for application fees), when will those be provided?
3. Re Section 3.2, why is the applicant providing information on when ICANN last performed a background check on the applicant’s affiliated entity? Doesn’t ICANN know this? I would like to reiterate Volker’s position that background checks should not be required for affiliated entities. If a check has already been conducted on an affiliated entity, responses to the questions in the rest of section 3 should be sufficient.
4. Re 5.2: I lost track of where we are on identifying that the registration is a privacy/proxy registration, but wasn’t this concern already accounted for in the rules generally? I don’t think it should solved by providers individually and therefore this question is not necessary.
5. Generally, the change from asking for descriptions to asking for confirmation is welcome.
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 Caitlin Tubergen SENT: Wednesday, October 04, 2017 6:36 PM TO: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> SUBJECT: [Gdd-gnso-ppsai-impl] Materials, action items from 3 October Privacy/Proxy IRT call
Dear Colleagues,
Thank you for your participation on the last Privacy/Proxy IRT call on Tuesday, 3 October. For those who could not attend, I encourage you to review the recording (HTTPS://PARTICIPATE.ICANN.ORG/P8DNKIUB56V/<HTTPS://PARTICIPATE.ICANN.ORG/P8DNKIUB56V/> [1]) and materials on the wiki, https://community.icann.org/display/IRT/03+October+2017<https://community.icann.org/display/IRT/03+October+2017> [2].
I attached two documents for your review:
(1) The updated Applicant Guidebook/Application (v3)
(2) The updated De-Accreditation Procedure (v2)
NOTES ON UPDATED APPLICANT GUIDE
We received feedback from the IRT that the application process should be simplified, which included (1) consolidation of “tracks”, i.e., rather than four tracks, there should be two tracks: unaffiliated entities and affiliated entities; (2) a streamlined application, which includes only necessary long-form/essay questions and a “check box”, short form for the majority of questions. Further to that feedback, please review the next iteration (v3) of the Applicant Guidebook, with particular attention to Sections 5-6 (p. 10-11). Please provide any additional feedback to the list by TUESDAY, 10 OCTOBER. We will discuss any updates on our call next Tuesday.
NOTES ON DE-ACCREDITATION PROCEDURE
Further to your feedback on the last call about de-accreditation, we removed the text in section 2.4.6 about a customer’s personal information being revealed in WHOIS following a termination of a P/P Provider to reflect the reality of a termination, which would involve a potential suspension (per the Whois Accuracy Program Specification (WAPS) as opposed to publication of underlying customer information in RDDS. A few members of the IRT expressed concern with treating the information as inaccurate and suspending names after 15 days, per the WAPS. We proposed to change that period to 30 DAYS, i.e., following a termination of a P/P provider, the gaining provider/registrar would have 30 days to contact the customers to correct the inaccurate WHOIS information before potential suspension.
Additionally, a member of the IRT expressed a concern as to which entity (the terminated or gaining provider) would be in charge of processing abuse complaints during terminations. Until the date of P/P provider is terminated, the terminating provider would be responsible for handling abuse tickets, as that entity would still be under contract. Following the termination date, the new provider would be responsible for processing abuse complaints. A member of the IRT noted a potential gap, where an individual/entity may file a complaint with the terminating entity, but if it is not responded to, it would need to file a new version of the same complaint with the gaining entity. If you have any suggestions about how this should be handled, please feel free to make suggestions to the list by TUESDAY, 10 OCTOBER.
On our next call on Tuesday, 10 October, we will be discussing the proposed updates to the attached documents. I am also hoping to have the next iteration of the Accreditaiton Agreement to share with you early next week.
Thank you again for all of your work on this!
Best regards,
Caitlin
Links: ------ [1] https://participate.icann.org/p8dnkiub56v/?OWASP_CSRFTOKEN=ebda0b0ecee56f6650584ca3c6df298c9b9b9d14eecf0b0d980f2dd84f7c45cb<https://participate.icann.org/p8dnkiub56v/?OWASP_CSRFTOKEN=ebda0b0ecee56f6650584ca3c6df298c9b9b9d14eecf0b0d980f2dd84f7c45cb> [2] https://community.icann.org/display/IRT/03+October+2017<https://community.icann.org/display/IRT/03+October+2017> _______________________________________________ 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>
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participants (4)
-
Caitlin Tubergen -
DiBiase, Gregory -
gtheo -
Metalitz, Steven