Updated PP De-Accreditation Procedure Document Attached for IRT review
Dear Colleagues, Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list. We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week. Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>
Hi Any, et al, 4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here. I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also? Thanks, Theo Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1] http://www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Theo, Thanks for your feedback. This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer. There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement? Best, Amy -----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review Hi Any, et al, 4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here. I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also? Thanks, Theo Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote: > Hi Theo, > > Thanks for your feedback. > > This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer. > > There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement? > > Best, > Amy > > -----Original Message----- > From: gtheo [mailto:gtheo@xs4all.nl] > Sent: Thursday, July 26, 2018 4:54 AM > To: gdd-gnso-ppsai-impl@icann.org > Cc: Amy Bivins <amy.bivins@icann.org> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review > > Hi Any, et al, > > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? > I am somewhat struggling here with what we want to achieve and what a privacy provider can do here. > > I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also? > > Thanks, > > Theo > > > > Amy Bivins schreef op 2018-07-25 03:37 PM: >> Dear Colleagues, >> >> Attached you will find a new draft of the PP De-accreditation and >> transition procedure, updated based on IRT feedback and our final >> (prior to public comment) internal review. If you have any further >> questions or comments on this document, please send them to the list. >> >> We're nearly finished with the final editing/review process for the >> applicant guide and fees document, as well (there will be copy edits >> but no significant substantive changes). I'll send those to the list >> as soon as they are complete, likely before the end of this week. >> >> Best, >> >> Amy >> >> AMY E. BIVINS >> >> Registrar Services and Engagement Senior Manager >> >> Registrar Services and Industry Relations >> >> Internet Corporation for Assigned Names and Numbers (ICANN) >> >> Direct: +1 (202) 249-7551 >> >> Fax: +1 (202) 789-0104 >> >> Email: amy.bivins@icann.org >> >> www.icann.org [1] >> >> >> >> Links: >> ------ >> [1] >> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted. I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC. The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC. Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long. A bulk transfer at a registry level, poorly communicated could create chaos. Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed. Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing? For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar. Thanks! Theo Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider.
Sara
sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey
This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.
On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote:
Hi Amy,
If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar?
I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here?
Thanks, Theo
On 26-7-2018 15:03, Amy Bivins wrote: > Hi Theo, > > Thanks for your feedback. > > This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer. > > There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement? > > Best, > Amy > > -----Original Message----- > From: gtheo [mailto:gtheo@xs4all.nl] > Sent: Thursday, July 26, 2018 4:54 AM > To: gdd-gnso-ppsai-impl@icann.org > Cc: Amy Bivins <amy.bivins@icann.org> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review > > Hi Any, et al, > > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? > I am somewhat struggling here with what we want to achieve and what a privacy provider can do here. > > I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also? > > Thanks, > > Theo > > > > Amy Bivins schreef op 2018-07-25 03:37 PM: >> Dear Colleagues, >> >> Attached you will find a new draft of the PP De-accreditation and >> transition procedure, updated based on IRT feedback and our final >> (prior to public comment) internal review. If you have any further >> questions or comments on this document, please send them to the list. >> >> We're nearly finished with the final editing/review process for the >> applicant guide and fees document, as well (there will be copy edits >> but no significant substantive changes). I'll send those to the list >> as soon as they are complete, likely before the end of this week. >> >> Best, >> >> Amy >> >> AMY E. BIVINS >> >> Registrar Services and Engagement Senior Manager >> >> Registrar Services and Industry Relations >> >> Internet Corporation for Assigned Names and Numbers (ICANN) >> >> Direct: +1 (202) 249-7551 >> >> Fax: +1 (202) 789-0104 >> >> Email: amy.bivins@icann.org >> >> www.icann.org [1] >> >> >> >> Links: >> ------ >> [1] >> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes. Sara Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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
Thanks, Sara and Theo for your feedback on this. I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week. To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider. Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis). Thanks, all, and have a great weekend. Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes. Sara Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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
Hi Amy, Correct me if I am wrong, but does that imply the proposed fees are based on the onboarding, but there are no details regarding the operational costs? Thanks, Theo Amy Bivins schreef op 2018-08-03 07:34 PM:
Thanks, Sara and Theo for your feedback on this.
I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week.
To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider.
Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis).
Thanks, all, and have a great weekend.
Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes.
Sara
Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1]
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Amy, transition is just as bad. There simply is no reason why a termination of a privacy service provider would necessitate or even justify a registrar transfer. Requiring registrar coordination does not help either. The registrant expects to find the domain names he owns in the user account with the provider he chose, not with another registrar he has no agreement with, has not provided payment details to. etc. You are creating a nightmare for registrars and registrants alike, with no justification from anything the WG decided. Oh, and the fees need to go! Best, Volker Am 06.08.2018 um 09:53 schrieb gtheo:
Hi Amy,
Correct me if I am wrong, but does that imply the proposed fees are based on the onboarding, but there are no details regarding the operational costs?
Thanks,
Theo
Amy Bivins schreef op 2018-08-03 07:34 PM:
Thanks, Sara and Theo for your feedback on this.
I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week.
To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider.
Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis).
Thanks, all, and have a great weekend.
Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes.
Sara
Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote: > Hi Theo, > > Thanks for your feedback. > > This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer. > > There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement? > > Best, > Amy > > -----Original Message----- > From: gtheo [mailto:gtheo@xs4all.nl] > Sent: Thursday, July 26, 2018 4:54 AM > To: gdd-gnso-ppsai-impl@icann.org > Cc: Amy Bivins <amy.bivins@icann.org> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review > > Hi Any, et al, > > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? > I am somewhat struggling here with what we want to achieve and what a privacy provider can do here. > > I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also? > > Thanks, > > Theo > > > > Amy Bivins schreef op 2018-07-25 03:37 PM: >> Dear Colleagues, >> >> Attached you will find a new draft of the PP De-accreditation and >> transition procedure, updated based on IRT feedback and our final >> (prior to public comment) internal review. If you have any further >> questions or comments on this document, please send them to the list. >> >> We're nearly finished with the final editing/review process for the >> applicant guide and fees document, as well (there will be copy edits >> but no significant substantive changes). I'll send those to the list >> as soon as they are complete, likely before the end of this week. >> >> Best, >> >> Amy >> >> AMY E. BIVINS >> >> Registrar Services and Engagement Senior Manager >> >> Registrar Services and Industry Relations >> >> Internet Corporation for Assigned Names and Numbers (ICANN) >> >> Direct: +1 (202) 249-7551 >> >> Fax: +1 (202) 789-0104 >> >> Email: amy.bivins@icann.org >> >> www.icann.org [1] >> >> >> >> Links: >> ------ >> [1] >> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
Agree with Volker. I don't think using the word "transition" helps and the idea that changing PP Provider requires a change of registrar is just wrong. The Provider is a separate entity from the registrar. Registrars need the ability to contract with a new PP Provider should a Provider's service be terminated. Sara Bockey GoDaddy | Senior Policy Manager +1 480-366-3616 sbockey@godaddy.com This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 8/6/18, 3:54 AM, "Gdd-gnso-ppsai-impl on behalf of Volker Greimann" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of vgreimann@key-systems.net> wrote: Hi Amy, transition is just as bad. There simply is no reason why a termination of a privacy service provider would necessitate or even justify a registrar transfer. Requiring registrar coordination does not help either. The registrant expects to find the domain names he owns in the user account with the provider he chose, not with another registrar he has no agreement with, has not provided payment details to. etc. You are creating a nightmare for registrars and registrants alike, with no justification from anything the WG decided. Oh, and the fees need to go! Best, Volker Am 06.08.2018 um 09:53 schrieb gtheo: > Hi Amy, > > Correct me if I am wrong, but does that imply the proposed fees are > based on the onboarding, but there are no details regarding the > operational costs? > > Thanks, > > Theo > > > Amy Bivins schreef op 2018-08-03 07:34 PM: >> Thanks, Sara and Theo for your feedback on this. >> >> I'm working on some proposed edits to this document based on your >> feedback--once I can discuss with Legal I'll have an updated draft for >> you. I hope to be able to send a draft to the list next week. >> >> To start, we're planning to change the word "transfer" to "transition" >> and to explicitly require coordination with the registrar as a >> necessary step for a bulk transition. We're also taking another look >> at notice requirements where a registrar is not involved in the >> facilitation of a bulk transfer, in which case a customer might need >> to transfer out if the customer wishes to transition to a new PP >> service provider. >> >> Theo, regarding your comments on the fees proposal, the activities >> listed as contributors to ongoing expected program costs (one of the 3 >> elements that fed into the proposed fees determination) were not >> itemized the way they were for the application phase (this would >> require a broader analysis). >> >> Thanks, all, and have a great weekend. >> >> Amy >> >> >> >> -----Original Message----- >> From: Gdd-gnso-ppsai-impl >> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara >> Bockey >> Sent: Tuesday, July 31, 2018 8:31 AM >> To: gdd-gnso-ppsai-impl@icann.org >> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP >> De-Accreditation Procedure Document Attached for IRT review >> >> Again. Agree with Theo. Use of the word “transfer” is confusing and >> problematic. We need to be able to reassign the service, contract >> with a new provider. Actual transfers would seem to be a dead last >> option. We don’t want to penalize the customer just because the P/P >> service changes. >> >> Sara >> >> Sent from my iPhone. Apologies for typos and/or brevity. >> >>> On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote: >>> >>> I think the word transfer is somewhat confusing or does not meet the >>> objective or can cause results that are not wanted. >>> >>> I can imagine a reseller using privacy provider X. >>> Privacy Provider X merges or hands over the business to Privacy >>> Provider ABC. >>> >>> The most logical path is that the reseller updates the domain names >>> to the details of Privacy Provider ABC. >>> >>> Transfering the domain names in bulk or through an inter-registrar >>> transfer to the registrar of privacy provider ABC could be not >>> wanted for various reasons. >>> Reseller has to implement a new API with the new registrar. >>> Billing issues. >>> The new registrar may lack features key critical to the reseller at >>> the current registrar. >>> Etc the list is long. >>> >>> A bulk transfer at a registry level, poorly communicated could >>> create chaos. >>> >>> Regarding the fees. The fee document seems to have two major >>> components. >>> Program Startup and Application Processing Here are all the costs >>> listed. >>> >>> Then there is the; Ongoing Accreditation Program Maintenance Here are >>> no fees listed. >>> Are the fees of the ongoing program maintenance listed in the >>> program startup and application processing? >>> >>> For example, Complaint processing is listed as ongoing. What are >>> those costs? Or can I simply exclude them as those costs are not >>> taken into account? How does that work? >>> I think it is relevant as I expect complaint processing cannot be >>> compared to the current situation in case of a registrar. >>> >>> Thanks! >>> Theo >>> >>> >>> Sara Bockey schreef op 2018-07-30 10:31 PM: >>>> Apologies for weighing in late here, but I agree with Theo. I'm not >>>> understanding why the registrar would need to change per se. I also >>>> can imagine a scenario where a privacy provider (or registrar) >>>> reaches an agreement with another privacy provider to provide >>>> privacy. In fact, I think this would be the most likely option we >>>> would want - allow the registrar to contract with a new provider. >>>> Sara >>>> sara bockey >>>> sr. policy manager | GoDaddy™ >>>> sbockey@godaddy.com 480-366-3616 >>>> skype: sbockey >>>> This email message and any attachments hereto is intended for use >>>> only by the addressee(s) named herein and may contain confidential >>>> information. If you have received this email in error, please >>>> immediately notify the sender and permanently delete the original and >>>> any copy of this message and its attachments. >>>> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" >>>> <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> >>>> wrote: >>>> Hi Amy, >>>> If it is supposed to address both situations, isn't it somewhat >>>> odd a >>>> privacy provider can order a bulk transfer to another privacy >>>> provider >>>> at another registrar? >>>> I can imagine a scenario where a privacy provider reaches an >>>> agreement >>>> with another privacy provider to update all the domain names to one >>>> privacy provider. But to transfer domain names in bulk in the above >>>> scenario, does that benefit the registrant? I think it could create >>>> total chaos and disruption of services. Or is the above scenario >>>> unthinkable and am I chasing ghosts here? >>>> Thanks, >>>> Theo >>>> On 26-7-2018 15:03, Amy Bivins wrote: >>>> > Hi Theo, >>>> > >>>> > Thanks for your feedback. >>>> > >>>> > This was drafted to try to accommodate both types of situations, >>>> though, practically speaking, it seems probable that in most cases >>>> this would often involve an inter-registrar transfer. >>>> > >>>> > There's nothing explicit in the document that would require >>>> obtaining consent from the registrar to a provider-provider bulk >>>> transfer under the same registrar. Do you (and others) think this >>>> should be an explicit requirement? >>>> > >>>> > Best, >>>> > Amy >>>> > >>>> > -----Original Message----- >>>> > From: gtheo [mailto:gtheo@xs4all.nl] >>>> > Sent: Thursday, July 26, 2018 4:54 AM >>>> > To: gdd-gnso-ppsai-impl@icann.org >>>> > Cc: Amy Bivins <amy.bivins@icann.org> >>>> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP >>>> De-Accreditation Procedure Document Attached for IRT review >>>> > >>>> > Hi Any, et al, >>>> > >>>> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from >>>> one privacy provider to another, or can a privacy provider request a >>>> transfer of all the domain names that are being used by a privacy >>>> provider at a registrar to another privacy provider at another >>>> registrar? >>>> > I am somewhat struggling here with what we want to achieve and >>>> what a privacy provider can do here. >>>> > >>>> > I think in all cases when a privacy provider requests a bulk >>>> transfer the sponsoring registrar has to agree also? >>>> > >>>> > Thanks, >>>> > >>>> > Theo >>>> > >>>> > >>>> > >>>> > Amy Bivins schreef op 2018-07-25 03:37 PM: >>>> >> Dear Colleagues, >>>> >> >>>> >> Attached you will find a new draft of the PP De-accreditation >>>> and >>>> >> transition procedure, updated based on IRT feedback and our >>>> final >>>> >> (prior to public comment) internal review. If you have any >>>> further >>>> >> questions or comments on this document, please send them to >>>> the list. >>>> >> >>>> >> We're nearly finished with the final editing/review process >>>> for the >>>> >> applicant guide and fees document, as well (there will be >>>> copy edits >>>> >> but no significant substantive changes). I'll send those to >>>> the list >>>> >> as soon as they are complete, likely before the end of this >>>> week. >>>> >> >>>> >> Best, >>>> >> >>>> >> Amy >>>> >> >>>> >> AMY E. BIVINS >>>> >> >>>> >> Registrar Services and Engagement Senior Manager >>>> >> >>>> >> Registrar Services and Industry Relations >>>> >> >>>> >> Internet Corporation for Assigned Names and Numbers (ICANN) >>>> >> >>>> >> Direct: +1 (202) 249-7551 >>>> >> >>>> >> Fax: +1 (202) 789-0104 >>>> >> >>>> >> Email: amy.bivins@icann.org >>>> >> >>>> >> www.icann.org [1] >>>> >> >>>> >> >>>> >> >>>> >> Links: >>>> >> ------ >>>> >> [1] >>>> >> >>>> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >>>> >> >>>> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >>>> >> >>>> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >>>> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >>>> >> _______________________________________________ >>>> >> Gdd-gnso-ppsai-impl mailing list >>>> >> Gdd-gnso-ppsai-impl@icann.org >>>> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> Gdd-gnso-ppsai-impl mailing list >>>> Gdd-gnso-ppsai-impl@icann.org >>>> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> 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 >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl > _______________________________________________ > Gdd-gnso-ppsai-impl mailing list > Gdd-gnso-ppsai-impl@icann.org > https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone. _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Sara and Volker (and all), I believe the summary of where we are proceeding based on your feedback was misunderstood--we are looking at a bulk transition to a new provider, as you recommend here, in cases where the registrar will cooperate and wishes to contract with a new PP provider. We are not talking about an inter-registrar bulk transfer. I think this will be more clear once the group is able to review proposed revisions to the document. Best, Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Monday, August 6, 2018 2:44 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Agree with Volker. I don't think using the word "transition" helps and the idea that changing PP Provider requires a change of registrar is just wrong. The Provider is a separate entity from the registrar. Registrars need the ability to contract with a new PP Provider should a Provider's service be terminated. Sara Bockey GoDaddy | Senior Policy Manager +1 480-366-3616 sbockey@godaddy.com This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 8/6/18, 3:54 AM, "Gdd-gnso-ppsai-impl on behalf of Volker Greimann" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of vgreimann@key-systems.net> wrote: Hi Amy, transition is just as bad. There simply is no reason why a termination of a privacy service provider would necessitate or even justify a registrar transfer. Requiring registrar coordination does not help either. The registrant expects to find the domain names he owns in the user account with the provider he chose, not with another registrar he has no agreement with, has not provided payment details to. etc. You are creating a nightmare for registrars and registrants alike, with no justification from anything the WG decided. Oh, and the fees need to go! Best, Volker Am 06.08.2018 um 09:53 schrieb gtheo: > Hi Amy, > > Correct me if I am wrong, but does that imply the proposed fees are > based on the onboarding, but there are no details regarding the > operational costs? > > Thanks, > > Theo > > > Amy Bivins schreef op 2018-08-03 07:34 PM: >> Thanks, Sara and Theo for your feedback on this. >> >> I'm working on some proposed edits to this document based on your >> feedback--once I can discuss with Legal I'll have an updated draft for >> you. I hope to be able to send a draft to the list next week. >> >> To start, we're planning to change the word "transfer" to "transition" >> and to explicitly require coordination with the registrar as a >> necessary step for a bulk transition. We're also taking another look >> at notice requirements where a registrar is not involved in the >> facilitation of a bulk transfer, in which case a customer might need >> to transfer out if the customer wishes to transition to a new PP >> service provider. >> >> Theo, regarding your comments on the fees proposal, the activities >> listed as contributors to ongoing expected program costs (one of the 3 >> elements that fed into the proposed fees determination) were not >> itemized the way they were for the application phase (this would >> require a broader analysis). >> >> Thanks, all, and have a great weekend. >> >> Amy >> >> >> >> -----Original Message----- >> From: Gdd-gnso-ppsai-impl >> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara >> Bockey >> Sent: Tuesday, July 31, 2018 8:31 AM >> To: gdd-gnso-ppsai-impl@icann.org >> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP >> De-Accreditation Procedure Document Attached for IRT review >> >> Again. Agree with Theo. Use of the word “transfer” is confusing and >> problematic. We need to be able to reassign the service, contract >> with a new provider. Actual transfers would seem to be a dead last >> option. We don’t want to penalize the customer just because the P/P >> service changes. >> >> Sara >> >> Sent from my iPhone. Apologies for typos and/or brevity. >> >>> On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote: >>> >>> I think the word transfer is somewhat confusing or does not meet the >>> objective or can cause results that are not wanted. >>> >>> I can imagine a reseller using privacy provider X. >>> Privacy Provider X merges or hands over the business to Privacy >>> Provider ABC. >>> >>> The most logical path is that the reseller updates the domain names >>> to the details of Privacy Provider ABC. >>> >>> Transfering the domain names in bulk or through an inter-registrar >>> transfer to the registrar of privacy provider ABC could be not >>> wanted for various reasons. >>> Reseller has to implement a new API with the new registrar. >>> Billing issues. >>> The new registrar may lack features key critical to the reseller at >>> the current registrar. >>> Etc the list is long. >>> >>> A bulk transfer at a registry level, poorly communicated could >>> create chaos. >>> >>> Regarding the fees. The fee document seems to have two major >>> components. >>> Program Startup and Application Processing Here are all the costs >>> listed. >>> >>> Then there is the; Ongoing Accreditation Program Maintenance Here are >>> no fees listed. >>> Are the fees of the ongoing program maintenance listed in the >>> program startup and application processing? >>> >>> For example, Complaint processing is listed as ongoing. What are >>> those costs? Or can I simply exclude them as those costs are not >>> taken into account? How does that work? >>> I think it is relevant as I expect complaint processing cannot be >>> compared to the current situation in case of a registrar. >>> >>> Thanks! >>> Theo >>> >>> >>> Sara Bockey schreef op 2018-07-30 10:31 PM: >>>> Apologies for weighing in late here, but I agree with Theo. I'm not >>>> understanding why the registrar would need to change per se. I also >>>> can imagine a scenario where a privacy provider (or registrar) >>>> reaches an agreement with another privacy provider to provide >>>> privacy. In fact, I think this would be the most likely option we >>>> would want - allow the registrar to contract with a new provider. >>>> Sara >>>> sara bockey >>>> sr. policy manager | GoDaddy™ >>>> sbockey@godaddy.com 480-366-3616 >>>> skype: sbockey >>>> This email message and any attachments hereto is intended for use >>>> only by the addressee(s) named herein and may contain confidential >>>> information. If you have received this email in error, please >>>> immediately notify the sender and permanently delete the original and >>>> any copy of this message and its attachments. >>>> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" >>>> <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> >>>> wrote: >>>> Hi Amy, >>>> If it is supposed to address both situations, isn't it somewhat >>>> odd a >>>> privacy provider can order a bulk transfer to another privacy >>>> provider >>>> at another registrar? >>>> I can imagine a scenario where a privacy provider reaches an >>>> agreement >>>> with another privacy provider to update all the domain names to one >>>> privacy provider. But to transfer domain names in bulk in the above >>>> scenario, does that benefit the registrant? I think it could create >>>> total chaos and disruption of services. Or is the above scenario >>>> unthinkable and am I chasing ghosts here? >>>> Thanks, >>>> Theo >>>> On 26-7-2018 15:03, Amy Bivins wrote: >>>> > Hi Theo, >>>> > >>>> > Thanks for your feedback. >>>> > >>>> > This was drafted to try to accommodate both types of situations, >>>> though, practically speaking, it seems probable that in most cases >>>> this would often involve an inter-registrar transfer. >>>> > >>>> > There's nothing explicit in the document that would require >>>> obtaining consent from the registrar to a provider-provider bulk >>>> transfer under the same registrar. Do you (and others) think this >>>> should be an explicit requirement? >>>> > >>>> > Best, >>>> > Amy >>>> > >>>> > -----Original Message----- >>>> > From: gtheo [mailto:gtheo@xs4all.nl] >>>> > Sent: Thursday, July 26, 2018 4:54 AM >>>> > To: gdd-gnso-ppsai-impl@icann.org >>>> > Cc: Amy Bivins <amy.bivins@icann.org> >>>> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP >>>> De-Accreditation Procedure Document Attached for IRT review >>>> > >>>> > Hi Any, et al, >>>> > >>>> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from >>>> one privacy provider to another, or can a privacy provider request a >>>> transfer of all the domain names that are being used by a privacy >>>> provider at a registrar to another privacy provider at another >>>> registrar? >>>> > I am somewhat struggling here with what we want to achieve and >>>> what a privacy provider can do here. >>>> > >>>> > I think in all cases when a privacy provider requests a bulk >>>> transfer the sponsoring registrar has to agree also? >>>> > >>>> > Thanks, >>>> > >>>> > Theo >>>> > >>>> > >>>> > >>>> > Amy Bivins schreef op 2018-07-25 03:37 PM: >>>> >> Dear Colleagues, >>>> >> >>>> >> Attached you will find a new draft of the PP De-accreditation >>>> and >>>> >> transition procedure, updated based on IRT feedback and our >>>> final >>>> >> (prior to public comment) internal review. If you have any >>>> further >>>> >> questions or comments on this document, please send them to >>>> the list. >>>> >> >>>> >> We're nearly finished with the final editing/review process >>>> for the >>>> >> applicant guide and fees document, as well (there will be >>>> copy edits >>>> >> but no significant substantive changes). I'll send those to >>>> the list >>>> >> as soon as they are complete, likely before the end of this >>>> week. >>>> >> >>>> >> Best, >>>> >> >>>> >> Amy >>>> >> >>>> >> AMY E. BIVINS >>>> >> >>>> >> Registrar Services and Engagement Senior Manager >>>> >> >>>> >> Registrar Services and Industry Relations >>>> >> >>>> >> Internet Corporation for Assigned Names and Numbers (ICANN) >>>> >> >>>> >> Direct: +1 (202) 249-7551 >>>> >> >>>> >> Fax: +1 (202) 789-0104 >>>> >> >>>> >> Email: amy.bivins@icann.org >>>> >> >>>> >> www.icann.org [1] >>>> >> >>>> >> >>>> >> >>>> >> Links: >>>> >> ------ >>>> >> [1] >>>> >> >>>> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >>>> >> >>>> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >>>> >> >>>> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >>>> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >>>> >> _______________________________________________ >>>> >> Gdd-gnso-ppsai-impl mailing list >>>> >> Gdd-gnso-ppsai-impl@icann.org >>>> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> Gdd-gnso-ppsai-impl mailing list >>>> Gdd-gnso-ppsai-impl@icann.org >>>> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> 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 >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl > _______________________________________________ > Gdd-gnso-ppsai-impl mailing list > Gdd-gnso-ppsai-impl@icann.org > https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone. _______________________________________________ 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
Apologies, I should have finished that thought before hitting send. The reference to an inter-registrar bulk transfer would be in the circumstance where a PP provider is terminated, and the registrar elects not to contract with any new PP provider (so that a customer could not use a PP provider at that registrar at all). In that instance, the draft procedure would require a notice to the customer alerting the customer that they would have the option to initiate an inter-registrar transfer if they do not wish to continue to have their name with a registrar where PP is not an option. I hope this makes sense. I hope to have this document ready for the group to review this week. Best, Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Monday, August 6, 2018 2:48 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Hi Sara and Volker (and all), I believe the summary of where we are proceeding based on your feedback was misunderstood--we are looking at a bulk transition to a new provider, as you recommend here, in cases where the registrar will cooperate and wishes to contract with a new PP provider. We are not talking about an inter-registrar bulk transfer. I think this will be more clear once the group is able to review proposed revisions to the document. Best, Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Monday, August 6, 2018 2:44 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Agree with Volker. I don't think using the word "transition" helps and the idea that changing PP Provider requires a change of registrar is just wrong. The Provider is a separate entity from the registrar. Registrars need the ability to contract with a new PP Provider should a Provider's service be terminated. Sara Bockey GoDaddy | Senior Policy Manager +1 480-366-3616 sbockey@godaddy.com This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 8/6/18, 3:54 AM, "Gdd-gnso-ppsai-impl on behalf of Volker Greimann" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of vgreimann@key-systems.net> wrote: Hi Amy, transition is just as bad. There simply is no reason why a termination of a privacy service provider would necessitate or even justify a registrar transfer. Requiring registrar coordination does not help either. The registrant expects to find the domain names he owns in the user account with the provider he chose, not with another registrar he has no agreement with, has not provided payment details to. etc. You are creating a nightmare for registrars and registrants alike, with no justification from anything the WG decided. Oh, and the fees need to go! Best, Volker Am 06.08.2018 um 09:53 schrieb gtheo: > Hi Amy, > > Correct me if I am wrong, but does that imply the proposed fees are > based on the onboarding, but there are no details regarding the > operational costs? > > Thanks, > > Theo > > > Amy Bivins schreef op 2018-08-03 07:34 PM: >> Thanks, Sara and Theo for your feedback on this. >> >> I'm working on some proposed edits to this document based on your >> feedback--once I can discuss with Legal I'll have an updated draft for >> you. I hope to be able to send a draft to the list next week. >> >> To start, we're planning to change the word "transfer" to "transition" >> and to explicitly require coordination with the registrar as a >> necessary step for a bulk transition. We're also taking another look >> at notice requirements where a registrar is not involved in the >> facilitation of a bulk transfer, in which case a customer might need >> to transfer out if the customer wishes to transition to a new PP >> service provider. >> >> Theo, regarding your comments on the fees proposal, the activities >> listed as contributors to ongoing expected program costs (one of the 3 >> elements that fed into the proposed fees determination) were not >> itemized the way they were for the application phase (this would >> require a broader analysis). >> >> Thanks, all, and have a great weekend. >> >> Amy >> >> >> >> -----Original Message----- >> From: Gdd-gnso-ppsai-impl >> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara >> Bockey >> Sent: Tuesday, July 31, 2018 8:31 AM >> To: gdd-gnso-ppsai-impl@icann.org >> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP >> De-Accreditation Procedure Document Attached for IRT review >> >> Again. Agree with Theo. Use of the word “transfer” is confusing and >> problematic. We need to be able to reassign the service, contract >> with a new provider. Actual transfers would seem to be a dead last >> option. We don’t want to penalize the customer just because the P/P >> service changes. >> >> Sara >> >> Sent from my iPhone. Apologies for typos and/or brevity. >> >>> On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote: >>> >>> I think the word transfer is somewhat confusing or does not meet the >>> objective or can cause results that are not wanted. >>> >>> I can imagine a reseller using privacy provider X. >>> Privacy Provider X merges or hands over the business to Privacy >>> Provider ABC. >>> >>> The most logical path is that the reseller updates the domain names >>> to the details of Privacy Provider ABC. >>> >>> Transfering the domain names in bulk or through an inter-registrar >>> transfer to the registrar of privacy provider ABC could be not >>> wanted for various reasons. >>> Reseller has to implement a new API with the new registrar. >>> Billing issues. >>> The new registrar may lack features key critical to the reseller at >>> the current registrar. >>> Etc the list is long. >>> >>> A bulk transfer at a registry level, poorly communicated could >>> create chaos. >>> >>> Regarding the fees. The fee document seems to have two major >>> components. >>> Program Startup and Application Processing Here are all the costs >>> listed. >>> >>> Then there is the; Ongoing Accreditation Program Maintenance Here are >>> no fees listed. >>> Are the fees of the ongoing program maintenance listed in the >>> program startup and application processing? >>> >>> For example, Complaint processing is listed as ongoing. What are >>> those costs? Or can I simply exclude them as those costs are not >>> taken into account? How does that work? >>> I think it is relevant as I expect complaint processing cannot be >>> compared to the current situation in case of a registrar. >>> >>> Thanks! >>> Theo >>> >>> >>> Sara Bockey schreef op 2018-07-30 10:31 PM: >>>> Apologies for weighing in late here, but I agree with Theo. I'm not >>>> understanding why the registrar would need to change per se. I also >>>> can imagine a scenario where a privacy provider (or registrar) >>>> reaches an agreement with another privacy provider to provide >>>> privacy. In fact, I think this would be the most likely option we >>>> would want - allow the registrar to contract with a new provider. >>>> Sara >>>> sara bockey >>>> sr. policy manager | GoDaddy™ >>>> sbockey@godaddy.com 480-366-3616 >>>> skype: sbockey >>>> This email message and any attachments hereto is intended for use >>>> only by the addressee(s) named herein and may contain confidential >>>> information. If you have received this email in error, please >>>> immediately notify the sender and permanently delete the original and >>>> any copy of this message and its attachments. >>>> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" >>>> <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> >>>> wrote: >>>> Hi Amy, >>>> If it is supposed to address both situations, isn't it somewhat >>>> odd a >>>> privacy provider can order a bulk transfer to another privacy >>>> provider >>>> at another registrar? >>>> I can imagine a scenario where a privacy provider reaches an >>>> agreement >>>> with another privacy provider to update all the domain names to one >>>> privacy provider. But to transfer domain names in bulk in the above >>>> scenario, does that benefit the registrant? I think it could create >>>> total chaos and disruption of services. Or is the above scenario >>>> unthinkable and am I chasing ghosts here? >>>> Thanks, >>>> Theo >>>> On 26-7-2018 15:03, Amy Bivins wrote: >>>> > Hi Theo, >>>> > >>>> > Thanks for your feedback. >>>> > >>>> > This was drafted to try to accommodate both types of situations, >>>> though, practically speaking, it seems probable that in most cases >>>> this would often involve an inter-registrar transfer. >>>> > >>>> > There's nothing explicit in the document that would require >>>> obtaining consent from the registrar to a provider-provider bulk >>>> transfer under the same registrar. Do you (and others) think this >>>> should be an explicit requirement? >>>> > >>>> > Best, >>>> > Amy >>>> > >>>> > -----Original Message----- >>>> > From: gtheo [mailto:gtheo@xs4all.nl] >>>> > Sent: Thursday, July 26, 2018 4:54 AM >>>> > To: gdd-gnso-ppsai-impl@icann.org >>>> > Cc: Amy Bivins <amy.bivins@icann.org> >>>> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP >>>> De-Accreditation Procedure Document Attached for IRT review >>>> > >>>> > Hi Any, et al, >>>> > >>>> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from >>>> one privacy provider to another, or can a privacy provider request a >>>> transfer of all the domain names that are being used by a privacy >>>> provider at a registrar to another privacy provider at another >>>> registrar? >>>> > I am somewhat struggling here with what we want to achieve and >>>> what a privacy provider can do here. >>>> > >>>> > I think in all cases when a privacy provider requests a bulk >>>> transfer the sponsoring registrar has to agree also? >>>> > >>>> > Thanks, >>>> > >>>> > Theo >>>> > >>>> > >>>> > >>>> > Amy Bivins schreef op 2018-07-25 03:37 PM: >>>> >> Dear Colleagues, >>>> >> >>>> >> Attached you will find a new draft of the PP De-accreditation >>>> and >>>> >> transition procedure, updated based on IRT feedback and our >>>> final >>>> >> (prior to public comment) internal review. If you have any >>>> further >>>> >> questions or comments on this document, please send them to >>>> the list. >>>> >> >>>> >> We're nearly finished with the final editing/review process >>>> for the >>>> >> applicant guide and fees document, as well (there will be >>>> copy edits >>>> >> but no significant substantive changes). I'll send those to >>>> the list >>>> >> as soon as they are complete, likely before the end of this >>>> week. >>>> >> >>>> >> Best, >>>> >> >>>> >> Amy >>>> >> >>>> >> AMY E. BIVINS >>>> >> >>>> >> Registrar Services and Engagement Senior Manager >>>> >> >>>> >> Registrar Services and Industry Relations >>>> >> >>>> >> Internet Corporation for Assigned Names and Numbers (ICANN) >>>> >> >>>> >> Direct: +1 (202) 249-7551 >>>> >> >>>> >> Fax: +1 (202) 789-0104 >>>> >> >>>> >> Email: amy.bivins@icann.org >>>> >> >>>> >> www.icann.org [1] >>>> >> >>>> >> >>>> >> >>>> >> Links: >>>> >> ------ >>>> >> [1] >>>> >> >>>> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >>>> >> >>>> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >>>> >> >>>> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >>>> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >>>> >> _______________________________________________ >>>> >> Gdd-gnso-ppsai-impl mailing list >>>> >> Gdd-gnso-ppsai-impl@icann.org >>>> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> Gdd-gnso-ppsai-impl mailing list >>>> Gdd-gnso-ppsai-impl@icann.org >>>> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> 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 >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl > _______________________________________________ > Gdd-gnso-ppsai-impl mailing list > Gdd-gnso-ppsai-impl@icann.org > https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone. _______________________________________________ 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
Thanks for the follow up, Amy. The PPSAI PDP was clear that P/P customers should be notified in advance of de-accreditation. I don't see where the PDP proposed a bulk "transition" option. Can you shed further light on the policy recommendation since I'm not finding it?
From an operational perspective, inserting a bulk "transition" piece really over complicates this. Registrars of record have to collaborate with or implement a P/P service (whether the registrar operates it or the registrar contracts with a third party). Just like any other service a registrar offers to a registrant in conjunction with domain name registration (e.g., hosting or email), the registrar will handle the decision of what to offer, how, etc. Inserting ICANN into managing the so-called "transition" isn't necessary.
Thanks, Darcy On Mon, Aug 6, 2018 at 11:51 AM Amy Bivins <amy.bivins@icann.org> wrote:
Apologies, I should have finished that thought before hitting send.
The reference to an inter-registrar bulk transfer would be in the circumstance where a PP provider is terminated, and the registrar elects not to contract with any new PP provider (so that a customer could not use a PP provider at that registrar at all). In that instance, the draft procedure would require a notice to the customer alerting the customer that they would have the option to initiate an inter-registrar transfer if they do not wish to continue to have their name with a registrar where PP is not an option. I hope this makes sense. I hope to have this document ready for the group to review this week.
Best, Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Monday, August 6, 2018 2:48 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Sara and Volker (and all),
I believe the summary of where we are proceeding based on your feedback was misunderstood--we are looking at a bulk transition to a new provider, as you recommend here, in cases where the registrar will cooperate and wishes to contract with a new PP provider. We are not talking about an inter-registrar bulk transfer. I think this will be more clear once the group is able to review proposed revisions to the document.
Best, Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Monday, August 6, 2018 2:44 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Agree with Volker. I don't think using the word "transition" helps and the idea that changing PP Provider requires a change of registrar is just wrong. The Provider is a separate entity from the registrar. Registrars need the ability to contract with a new PP Provider should a Provider's service be terminated.
Sara Bockey GoDaddy | Senior Policy Manager +1 480-366-3616 sbockey@godaddy.com
This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments.
On 8/6/18, 3:54 AM, "Gdd-gnso-ppsai-impl on behalf of Volker Greimann" < gdd-gnso-ppsai-impl-bounces@icann.org on behalf of vgreimann@key-systems.net> wrote:
Hi Amy,
transition is just as bad. There simply is no reason why a termination of a privacy service provider would necessitate or even justify a registrar transfer. Requiring registrar coordination does not help either. The registrant expects to find the domain names he owns in the user account with the provider he chose, not with another registrar he has no agreement with, has not provided payment details to. etc.
You are creating a nightmare for registrars and registrants alike, with no justification from anything the WG decided.
Oh, and the fees need to go!
Best,
Volker
Am 06.08.2018 um 09:53 schrieb gtheo: > Hi Amy, > > Correct me if I am wrong, but does that imply the proposed fees are > based on the onboarding, but there are no details regarding the > operational costs? > > Thanks, > > Theo > > > Amy Bivins schreef op 2018-08-03 07:34 PM: >> Thanks, Sara and Theo for your feedback on this. >> >> I'm working on some proposed edits to this document based on your >> feedback--once I can discuss with Legal I'll have an updated draft for >> you. I hope to be able to send a draft to the list next week. >> >> To start, we're planning to change the word "transfer" to "transition" >> and to explicitly require coordination with the registrar as a >> necessary step for a bulk transition. We're also taking another look >> at notice requirements where a registrar is not involved in the >> facilitation of a bulk transfer, in which case a customer might need >> to transfer out if the customer wishes to transition to a new PP >> service provider. >> >> Theo, regarding your comments on the fees proposal, the activities >> listed as contributors to ongoing expected program costs (one of the 3 >> elements that fed into the proposed fees determination) were not >> itemized the way they were for the application phase (this would >> require a broader analysis). >> >> Thanks, all, and have a great weekend. >> >> Amy >> >> >> >> -----Original Message----- >> From: Gdd-gnso-ppsai-impl >> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara >> Bockey >> Sent: Tuesday, July 31, 2018 8:31 AM >> To: gdd-gnso-ppsai-impl@icann.org >> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP >> De-Accreditation Procedure Document Attached for IRT review >> >> Again. Agree with Theo. Use of the word “transfer” is confusing and >> problematic. We need to be able to reassign the service, contract >> with a new provider. Actual transfers would seem to be a dead last >> option. We don’t want to penalize the customer just because the P/P >> service changes. >> >> Sara >> >> Sent from my iPhone. Apologies for typos and/or brevity. >> >>> On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote: >>> >>> I think the word transfer is somewhat confusing or does not meet the >>> objective or can cause results that are not wanted. >>> >>> I can imagine a reseller using privacy provider X. >>> Privacy Provider X merges or hands over the business to Privacy >>> Provider ABC. >>> >>> The most logical path is that the reseller updates the domain names >>> to the details of Privacy Provider ABC. >>> >>> Transfering the domain names in bulk or through an inter-registrar >>> transfer to the registrar of privacy provider ABC could be not >>> wanted for various reasons. >>> Reseller has to implement a new API with the new registrar. >>> Billing issues. >>> The new registrar may lack features key critical to the reseller at >>> the current registrar. >>> Etc the list is long. >>> >>> A bulk transfer at a registry level, poorly communicated could >>> create chaos. >>> >>> Regarding the fees. The fee document seems to have two major >>> components. >>> Program Startup and Application Processing Here are all the costs >>> listed. >>> >>> Then there is the; Ongoing Accreditation Program Maintenance Here are >>> no fees listed. >>> Are the fees of the ongoing program maintenance listed in the >>> program startup and application processing? >>> >>> For example, Complaint processing is listed as ongoing. What are >>> those costs? Or can I simply exclude them as those costs are not >>> taken into account? How does that work? >>> I think it is relevant as I expect complaint processing cannot be >>> compared to the current situation in case of a registrar. >>> >>> Thanks! >>> Theo >>> >>> >>> Sara Bockey schreef op 2018-07-30 10:31 PM: >>>> Apologies for weighing in late here, but I agree with Theo. I'm not >>>> understanding why the registrar would need to change per se. I also >>>> can imagine a scenario where a privacy provider (or registrar) >>>> reaches an agreement with another privacy provider to provide >>>> privacy. In fact, I think this would be the most likely option we >>>> would want - allow the registrar to contract with a new provider. >>>> Sara >>>> sara bockey >>>> sr. policy manager | GoDaddy™ >>>> sbockey@godaddy.com 480-366-3616 >>>> skype: sbockey >>>> This email message and any attachments hereto is intended for use >>>> only by the addressee(s) named herein and may contain confidential >>>> information. If you have received this email in error, please >>>> immediately notify the sender and permanently delete the original and >>>> any copy of this message and its attachments. >>>> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" >>>> <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> >>>> wrote: >>>> Hi Amy, >>>> If it is supposed to address both situations, isn't it somewhat >>>> odd a >>>> privacy provider can order a bulk transfer to another privacy >>>> provider >>>> at another registrar? >>>> I can imagine a scenario where a privacy provider reaches an >>>> agreement >>>> with another privacy provider to update all the domain names to one >>>> privacy provider. But to transfer domain names in bulk in the above >>>> scenario, does that benefit the registrant? I think it could create >>>> total chaos and disruption of services. Or is the above scenario >>>> unthinkable and am I chasing ghosts here? >>>> Thanks, >>>> Theo >>>> On 26-7-2018 15:03, Amy Bivins wrote: >>>> > Hi Theo, >>>> > >>>> > Thanks for your feedback. >>>> > >>>> > This was drafted to try to accommodate both types of situations, >>>> though, practically speaking, it seems probable that in most cases >>>> this would often involve an inter-registrar transfer. >>>> > >>>> > There's nothing explicit in the document that would require >>>> obtaining consent from the registrar to a provider-provider bulk >>>> transfer under the same registrar. Do you (and others) think this >>>> should be an explicit requirement? >>>> > >>>> > Best, >>>> > Amy >>>> > >>>> > -----Original Message----- >>>> > From: gtheo [mailto:gtheo@xs4all.nl] >>>> > Sent: Thursday, July 26, 2018 4:54 AM >>>> > To: gdd-gnso-ppsai-impl@icann.org >>>> > Cc: Amy Bivins <amy.bivins@icann.org> >>>> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP >>>> De-Accreditation Procedure Document Attached for IRT review >>>> > >>>> > Hi Any, et al, >>>> > >>>> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from >>>> one privacy provider to another, or can a privacy provider request a >>>> transfer of all the domain names that are being used by a privacy >>>> provider at a registrar to another privacy provider at another >>>> registrar? >>>> > I am somewhat struggling here with what we want to achieve and >>>> what a privacy provider can do here. >>>> > >>>> > I think in all cases when a privacy provider requests a bulk >>>> transfer the sponsoring registrar has to agree also? >>>> > >>>> > Thanks, >>>> > >>>> > Theo >>>> > >>>> > >>>> > >>>> > Amy Bivins schreef op 2018-07-25 03:37 PM: >>>> >> Dear Colleagues, >>>> >> >>>> >> Attached you will find a new draft of the PP De-accreditation >>>> and >>>> >> transition procedure, updated based on IRT feedback and our >>>> final >>>> >> (prior to public comment) internal review. If you have any >>>> further >>>> >> questions or comments on this document, please send them to >>>> the list. >>>> >> >>>> >> We're nearly finished with the final editing/review process >>>> for the >>>> >> applicant guide and fees document, as well (there will be >>>> copy edits >>>> >> but no significant substantive changes). I'll send those to >>>> the list >>>> >> as soon as they are complete, likely before the end of this >>>> week. >>>> >> >>>> >> Best, >>>> >> >>>> >> Amy >>>> >> >>>> >> AMY E. BIVINS >>>> >> >>>> >> Registrar Services and Engagement Senior Manager >>>> >> >>>> >> Registrar Services and Industry Relations >>>> >> >>>> >> Internet Corporation for Assigned Names and Numbers (ICANN) >>>> >> >>>> >> Direct: +1 (202) 249-7551 >>>> >> >>>> >> Fax: +1 (202) 789-0104 >>>> >> >>>> >> Email: amy.bivins@icann.org >>>> >> >>>> >> www.icann.org [1] >>>> >> >>>> >> >>>> >> >>>> >> Links: >>>> >> ------ >>>> >> [1] >>>> >> >>>> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >>>> >> >>>> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >>>> >> >>>> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >>>> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >>>> >> _______________________________________________ >>>> >> Gdd-gnso-ppsai-impl mailing list >>>> >> Gdd-gnso-ppsai-impl@icann.org >>>> >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> Gdd-gnso-ppsai-impl mailing list >>>> Gdd-gnso-ppsai-impl@icann.org >>>> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl >>>> _______________________________________________ >>>> 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 >> _______________________________________________ >> Gdd-gnso-ppsai-impl mailing list >> Gdd-gnso-ppsai-impl@icann.org >> https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl > _______________________________________________ > Gdd-gnso-ppsai-impl mailing list > Gdd-gnso-ppsai-impl@icann.org > https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
-- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung.
Mit freundlichen Grüßen,
Volker A. Greimann - Rechtsabteilung -
Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net
Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com
Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems www.twitter.com/key_systems
Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534
Member of the KEYDRIVE GROUP www.keydrive.lu
Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen.
--------------------------------------------
Should you have any further questions, please do not hesitate to contact us.
Best regards,
Volker A. Greimann - legal department -
Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net
Web: www.key-systems.net / www.RRPproxy.net www.domaindiscount24.com / www.BrandShelter.com
Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems www.twitter.com/key_systems
CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534
Member of the KEYDRIVE GROUP www.keydrive.lu
This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone.
_______________________________________________ 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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Thanks so much for your feedback, Darcy. We presented the rationale for this provision to the IRT back in April, but we didn’t receive any feedback on that from the IRT at that stage (this was around the same time as discussions on the LEA spec and fees, so this could have been overshadowed by those conversations). The draft transition process was included in the broader de-accreditation process as a protection for PP customers. The Final Recommendations provide than that termination should become effective 30 days after customers are notified, but there are no specific requirements in the policy recommendations related to how the termination process should be carried out. The process, other than the customer notice requirement, was modeled on the registrar de-accreditation process. I’ll take this feedback back to the internal team. Does anyone else have thoughts they would like to share about the inclusion of the proposed transition process generally, or specifics about it? Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Darcy Southwell Sent: Monday, August 6, 2018 3:37 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Thanks for the follow up, Amy. The PPSAI PDP was clear that P/P customers should be notified in advance of de-accreditation. I don't see where the PDP proposed a bulk "transition" option. Can you shed further light on the policy recommendation since I'm not finding it? From an operational perspective, inserting a bulk "transition" piece really over complicates this. Registrars of record have to collaborate with or implement a P/P service (whether the registrar operates it or the registrar contracts with a third party). Just like any other service a registrar offers to a registrant in conjunction with domain name registration (e.g., hosting or email), the registrar will handle the decision of what to offer, how, etc. Inserting ICANN into managing the so-called "transition" isn't necessary. Thanks, Darcy On Mon, Aug 6, 2018 at 11:51 AM Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Apologies, I should have finished that thought before hitting send. The reference to an inter-registrar bulk transfer would be in the circumstance where a PP provider is terminated, and the registrar elects not to contract with any new PP provider (so that a customer could not use a PP provider at that registrar at all). In that instance, the draft procedure would require a notice to the customer alerting the customer that they would have the option to initiate an inter-registrar transfer if they do not wish to continue to have their name with a registrar where PP is not an option. I hope this makes sense. I hope to have this document ready for the group to review this week. Best, Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Amy Bivins Sent: Monday, August 6, 2018 2:48 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Hi Sara and Volker (and all), I believe the summary of where we are proceeding based on your feedback was misunderstood--we are looking at a bulk transition to a new provider, as you recommend here, in cases where the registrar will cooperate and wishes to contract with a new PP provider. We are not talking about an inter-registrar bulk transfer. I think this will be more clear once the group is able to review proposed revisions to the document. Best, Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Sara Bockey Sent: Monday, August 6, 2018 2:44 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Agree with Volker. I don't think using the word "transition" helps and the idea that changing PP Provider requires a change of registrar is just wrong. The Provider is a separate entity from the registrar. Registrars need the ability to contract with a new PP Provider should a Provider's service be terminated. Sara Bockey GoDaddy | Senior Policy Manager +1 480-366-3616 sbockey@godaddy.com<mailto:sbockey@godaddy.com> This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 8/6/18, 3:54 AM, "Gdd-gnso-ppsai-impl on behalf of Volker Greimann" <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of vgreimann@key-systems.net<mailto:vgreimann@key-systems.net>> wrote: Hi Amy, transition is just as bad. There simply is no reason why a termination of a privacy service provider would necessitate or even justify a registrar transfer. Requiring registrar coordination does not help either. The registrant expects to find the domain names he owns in the user account with the provider he chose, not with another registrar he has no agreement with, has not provided payment details to. etc. You are creating a nightmare for registrars and registrants alike, with no justification from anything the WG decided. Oh, and the fees need to go! Best, Volker Am 06.08.2018 um 09:53 schrieb gtheo: > Hi Amy, > > Correct me if I am wrong, but does that imply the proposed fees are > based on the onboarding, but there are no details regarding the > operational costs? > > Thanks, > > Theo > > > Amy Bivins schreef op 2018-08-03 07:34 PM: >> Thanks, Sara and Theo for your feedback on this. >> >> I'm working on some proposed edits to this document based on your >> feedback--once I can discuss with Legal I'll have an updated draft for >> you. I hope to be able to send a draft to the list next week. >> >> To start, we're planning to change the word "transfer" to "transition" >> and to explicitly require coordination with the registrar as a >> necessary step for a bulk transition. We're also taking another look >> at notice requirements where a registrar is not involved in the >> facilitation of a bulk transfer, in which case a customer might need >> to transfer out if the customer wishes to transition to a new PP >> service provider. >> >> Theo, regarding your comments on the fees proposal, the activities >> listed as contributors to ongoing expected program costs (one of the 3 >> elements that fed into the proposed fees determination) were not >> itemized the way they were for the application phase (this would >> require a broader analysis). >> >> Thanks, all, and have a great weekend. >> >> Amy >> >> >> >> -----Original Message----- >> From: Gdd-gnso-ppsai-impl >> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Sara >> Bockey >> Sent: Tuesday, July 31, 2018 8:31 AM >> To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> >> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP >> De-Accreditation Procedure Document Attached for IRT review >> >> Again. Agree with Theo. Use of the word “transfer” is confusing and >> problematic. We need to be able to reassign the service, contract >> with a new provider. Actual transfers would seem to be a dead last >> option. We don’t want to penalize the customer just because the P/P >> service changes. >> >> Sara >> >> Sent from my iPhone. Apologies for typos and/or brevity. >> >>> On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: >>> >>> I think the word transfer is somewhat confusing or does not meet the >>> objective or can cause results that are not wanted. >>> >>> I can imagine a reseller using privacy provider X. >>> Privacy Provider X merges or hands over the business to Privacy >>> Provider ABC. >>> >>> The most logical path is that the reseller updates the domain names >>> to the details of Privacy Provider ABC. >>> >>> Transfering the domain names in bulk or through an inter-registrar >>> transfer to the registrar of privacy provider ABC could be not >>> wanted for various reasons. >>> Reseller has to implement a new API with the new registrar. >>> Billing issues. >>> The new registrar may lack features key critical to the reseller at >>> the current registrar. >>> Etc the list is long. >>> >>> A bulk transfer at a registry level, poorly communicated could >>> create chaos. >>> >>> Regarding the fees. The fee document seems to have two major >>> components. >>> Program Startup and Application Processing Here are all the costs >>> listed. >>> >>> Then there is the; Ongoing Accreditation Program Maintenance Here are >>> no fees listed. >>> Are the fees of the ongoing program maintenance listed in the >>> program startup and application processing? >>> >>> For example, Complaint processing is listed as ongoing. What are >>> those costs? Or can I simply exclude them as those costs are not >>> taken into account? How does that work? >>> I think it is relevant as I expect complaint processing cannot be >>> compared to the current situation in case of a registrar. >>> >>> Thanks! >>> Theo >>> >>> >>> Sara Bockey schreef op 2018-07-30 10:31 PM: >>>> Apologies for weighing in late here, but I agree with Theo. I'm not >>>> understanding why the registrar would need to change per se. I also >>>> can imagine a scenario where a privacy provider (or registrar) >>>> reaches an agreement with another privacy provider to provide >>>> privacy. In fact, I think this would be the most likely option we >>>> would want - allow the registrar to contract with a new provider. >>>> Sara >>>> sara bockey >>>> sr. policy manager | GoDaddy™ >>>> sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 >>>> skype: sbockey >>>> This email message and any attachments hereto is intended for use >>>> only by the addressee(s) named herein and may contain confidential >>>> information. If you have received this email in error, please >>>> immediately notify the sender and permanently delete the original and >>>> any copy of this message and its attachments. >>>> On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" >>>> <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> >>>> wrote: >>>> Hi Amy, >>>> If it is supposed to address both situations, isn't it somewhat >>>> odd a >>>> privacy provider can order a bulk transfer to another privacy >>>> provider >>>> at another registrar? >>>> I can imagine a scenario where a privacy provider reaches an >>>> agreement >>>> with another privacy provider to update all the domain names to one >>>> privacy provider. But to transfer domain names in bulk in the above >>>> scenario, does that benefit the registrant? I think it could create >>>> total chaos and disruption of services. Or is the above scenario >>>> unthinkable and am I chasing ghosts here? >>>> Thanks, >>>> Theo >>>> On 26-7-2018 15:03, Amy Bivins wrote: >>>> > Hi Theo, >>>> > >>>> > Thanks for your feedback. >>>> > >>>> > This was drafted to try to accommodate both types of situations, >>>> though, practically speaking, it seems probable that in most cases >>>> this would often involve an inter-registrar transfer. >>>> > >>>> > There's nothing explicit in the document that would require >>>> obtaining consent from the registrar to a provider-provider bulk >>>> transfer under the same registrar. Do you (and others) think this >>>> should be an explicit requirement? >>>> > >>>> > Best, >>>> > Amy >>>> > >>>> > -----Original Message----- >>>> > From: gtheo [mailto:gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>] >>>> > Sent: Thursday, July 26, 2018 4:54 AM >>>> > To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> >>>> > Cc: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> >>>> > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP >>>> De-Accreditation Procedure Document Attached for IRT review >>>> > >>>> > Hi Any, et al, >>>> > >>>> > 4.4 Voluntary Bulk Transfers, are we talking "transfers" from >>>> one privacy provider to another, or can a privacy provider request a >>>> transfer of all the domain names that are being used by a privacy >>>> provider at a registrar to another privacy provider at another >>>> registrar? >>>> > I am somewhat struggling here with what we want to achieve and >>>> what a privacy provider can do here. >>>> > >>>> > I think in all cases when a privacy provider requests a bulk >>>> transfer the sponsoring registrar has to agree also? >>>> > >>>> > Thanks, >>>> > >>>> > Theo >>>> > >>>> > >>>> > >>>> > Amy Bivins schreef op 2018-07-25 03:37 PM: >>>> >> Dear Colleagues, >>>> >> >>>> >> Attached you will find a new draft of the PP De-accreditation >>>> and >>>> >> transition procedure, updated based on IRT feedback and our >>>> final >>>> >> (prior to public comment) internal review. If you have any >>>> further >>>> >> questions or comments on this document, please send them to >>>> the list. >>>> >> >>>> >> We're nearly finished with the final editing/review process >>>> for the >>>> >> applicant guide and fees document, as well (there will be >>>> copy edits >>>> >> but no significant substantive changes). I'll send those to >>>> the list >>>> >> as soon as they are complete, likely before the end of this >>>> week. >>>> >> >>>> >> 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> [1] >>>> >> >>>> >> >>>> >> >>>> >> Links: >>>> >> ------ >>>> >> [1] >>>> >> >>>> https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw >>>> >> >>>> ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T >>>> >> >>>> plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A >>>> >> vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= >>>> >> _______________________________________________ >>>> >> 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 >>> _______________________________________________ >>> 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 > _______________________________________________ > 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 -- Bei weiteren Fragen stehen wir Ihnen gerne zur Verfügung. Mit freundlichen Grüßen, Volker A. Greimann - Rechtsabteilung - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Folgen Sie uns bei Twitter oder werden Sie unser Fan bei Facebook: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> Geschäftsführer: Alexander Siffrin Handelsregister Nr.: HR B 18835 - Saarbruecken Umsatzsteuer ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> Der Inhalt dieser Nachricht ist vertraulich und nur für den angegebenen Empfänger bestimmt. Jede Form der Kenntnisgabe, Veröffentlichung oder Weitergabe an Dritte durch den Empfänger ist unzulässig. Sollte diese Nachricht nicht für Sie bestimmt sein, so bitten wir Sie, sich mit uns per E-Mail oder telefonisch in Verbindung zu setzen. -------------------------------------------- Should you have any further questions, please do not hesitate to contact us. Best regards, Volker A. Greimann - legal department - Key-Systems GmbH Im Oberen Werk 1 66386 St. Ingbert Tel.: +49 (0) 6894 - 9396 901 Fax.: +49 (0) 6894 - 9396 851 Email: vgreimann@key-systems.net<mailto:vgreimann@key-systems.net> Web: www.key-systems.net<http://www.key-systems.net> / www.RRPproxy.net<http://www.RRPproxy.net> www.domaindiscount24.com<http://www.domaindiscount24.com> / www.BrandShelter.com<http://www.BrandShelter.com> Follow us on Twitter or join our fan community on Facebook and stay updated: www.facebook.com/KeySystems<http://www.facebook.com/KeySystems> www.twitter.com/key_systems<http://www.twitter.com/key_systems> CEO: Alexander Siffrin Registration No.: HR B 18835 - Saarbruecken V.A.T. ID.: DE211006534 Member of the KEYDRIVE GROUP www.keydrive.lu<http://www.keydrive.lu> This e-mail and its attachments is intended only for the person to whom it is addressed. Furthermore it is not permitted to publish any content of this email. You must not use, disclose, copy, print or rely on this e-mail. If an addressing or transmission error has misdirected this e-mail, kindly notify the author by replying to this e-mail or contacting us by telephone. _______________________________________________ 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 _______________________________________________ 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
Hi Theo, The fees proposal document noted that the proposed fee structure is based on three factors (anticipated costs is only one of those factors; the other two are benchmarks and transparency). ICANN provided an itemization of the anticipated costs with respect to the application fee, but not the annual fee. For the annual fee, ICANN identified the activities that are expected to contribute to the ongoing program management costs. ICANN did not specifically itemize specific costs associated with those activities, as they are part of day-to-day organizational operations and cannot be separated out from more general organizational costs. As noted in the document, ICANN will continue to seek feedback on this through the broader public comment process. I hope that helps. Amy -----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Monday, August 6, 2018 3:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Hi Amy, Correct me if I am wrong, but does that imply the proposed fees are based on the onboarding, but there are no details regarding the operational costs? Thanks, Theo Amy Bivins schreef op 2018-08-03 07:34 PM:
Thanks, Sara and Theo for your feedback on this.
I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week.
To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider.
Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis).
Thanks, all, and have a great weekend.
Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes.
Sara
Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1]
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Seems to me this is a simple case of caveat emptor! The P/P provider covenants that it has sold a service for which it is fully qualified to sell and provide, so far as that is required. The P/P customer accepts and covenants it has acquired the service in good faith and credit. P/P is not a baseline requirement pertaining stability and security of the DNS but an add-on choice. If the P/P provider turns out to be a scofflaw then the most that should happen is to *take due care* the P/P customer be given *due notice* that they bought a bill of goods and what is coming at them. And if they still need the conservation the service offers then they ought to go find another P/P service provider in good standing. -Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* ============================= On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins <amy.bivins@icann.org> wrote:
Thanks, Sara and Theo for your feedback on this.
I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week.
To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider.
Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis).
Thanks, all, and have a great weekend.
Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes.
Sara
Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1]
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Thanks, Carlton and all. For those who recommend that ICANN org drop any reference to a bulk transition procedure from a terminating PP to a new PP, even if the registrar wants and agrees to facilitate this, how do you see this working for customers once the provider is terminated? As the documents are drafted today, once a provider is terminated, the RDDS contact information is considered “inaccurate” for purposes of the registrar’s WHOIS accuracy program obligations under the RAA. At that stage, following the progression of the WHOIS Accuracy Program, the customers’ names could potentially be suspended by the registrar if the customer does not update the contact information (either their own, or by signing up for a new PP service) to correct the inaccuracy. Is that the intended result? Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Carlton Samuels Sent: Tuesday, August 7, 2018 12:11 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Seems to me this is a simple case of caveat emptor! The P/P provider covenants that it has sold a service for which it is fully qualified to sell and provide, so far as that is required. The P/P customer accepts and covenants it has acquired the service in good faith and credit. P/P is not a baseline requirement pertaining stability and security of the DNS but an add-on choice. If the P/P provider turns out to be a scofflaw then the most that should happen is to take due care the P/P customer be given due notice that they bought a bill of goods and what is coming at them. And if they still need the conservation the service offers then they ought to go find another P/P service provider in good standing. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround ============================= On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Thanks, Sara and Theo for your feedback on this. I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week. To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider. Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis). Thanks, all, and have a great weekend. Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes. Sara Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Cc: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
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> [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ 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
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
Dear Amy: What you have outlined is precisely what should happen. The licensor - ICANN org - has a duty of care to the licensee's customer. That duty to care is exercised by good faith effort of the licensor to contact and update the licensee's customer from the moment the licensee - the P/P provider is adjudged to be in breach. There is a timeline for breach remediation. Assuming the breach is not mended, then the de-accreditation process kicks in. In that communique to the P/P customer, the reasons will be outlined, the timeline for remediation and what will happen if not remediated; inaccurate WHOIS-RDS data which makes the domain name subject to suspension. That communique must outline the options available to that P/P customer if they wish to do to avoid that eventuality. I do not believe a registrar-marketing assist - which is what that bulk-transfer matter becomes for a favoured one is! - is ICANN's business. It is done. Leave it to the registrant to act in their best interest. -Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* ============================= On Tue, Aug 7, 2018 at 12:19 PM Amy Bivins <amy.bivins@icann.org> wrote:
Thanks, Carlton and all.
For those who recommend that ICANN org drop any reference to a bulk transition procedure from a terminating PP to a new PP, even if the registrar wants and agrees to facilitate this, how do you see this working for customers once the provider is terminated?
As the documents are drafted today, once a provider is terminated, the RDDS contact information is considered “inaccurate” for purposes of the registrar’s WHOIS accuracy program obligations under the RAA. At that stage, following the progression of the WHOIS Accuracy Program, the customers’ names could potentially be suspended by the registrar if the customer does not update the contact information (either their own, or by signing up for a new PP service) to correct the inaccuracy. Is that the intended result?
Best,
Amy
*From:* Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Carlton Samuels *Sent:* Tuesday, August 7, 2018 12:11 PM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Seems to me this is a simple case of caveat emptor! The P/P provider covenants that it has sold a service for which it is fully qualified to sell and provide, so far as that is required.
The P/P customer accepts and covenants it has acquired the service in good faith and credit.
P/P is not a baseline requirement pertaining stability and security of the DNS but an add-on choice. If the P/P provider turns out to be a scofflaw then the most that should happen is to *take due care* the P/P customer be given *due notice* that they bought a bill of goods and what is coming at them. And if they still need the conservation the service offers then they ought to go find another P/P service provider in good standing.
-Carlton
============================== *Carlton A Samuels*
*Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround* =============================
On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins <amy.bivins@icann.org> wrote:
Thanks, Sara and Theo for your feedback on this.
I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week.
To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider.
Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis).
Thanks, all, and have a great weekend.
Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes.
Sara
Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1]
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ 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
Carlton Sorry, but who is going to send this notice? If the provider is in breach it’s probably because they haven’t been able to comply with contractual obligations. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com https://blacknight.blog / http://ceo.hosting/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow, R93 X265 ,Ireland Company No.: 370845 From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Carlton Samuels <carlton.samuels@gmail.com> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Tuesday 7 August 2018 at 19:14 To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Dear Amy: What you have outlined is precisely what should happen. The licensor - ICANN org - has a duty of care to the licensee's customer. That duty to care is exercised by good faith effort of the licensor to contact and update the licensee's customer from the moment the licensee - the P/P provider is adjudged to be in breach. There is a timeline for breach remediation. Assuming the breach is not mended, then the de-accreditation process kicks in. In that communique to the P/P customer, the reasons will be outlined, the timeline for remediation and what will happen if not remediated; inaccurate WHOIS-RDS data which makes the domain name subject to suspension. That communique must outline the options available to that P/P customer if they wish to do to avoid that eventuality. I do not believe a registrar-marketing assist - which is what that bulk-transfer matter becomes for a favoured one is! - is ICANN's business. It is done. Leave it to the registrant to act in their best interest. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround ============================= On Tue, Aug 7, 2018 at 12:19 PM Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Thanks, Carlton and all. For those who recommend that ICANN org drop any reference to a bulk transition procedure from a terminating PP to a new PP, even if the registrar wants and agrees to facilitate this, how do you see this working for customers once the provider is terminated? As the documents are drafted today, once a provider is terminated, the RDDS contact information is considered “inaccurate” for purposes of the registrar’s WHOIS accuracy program obligations under the RAA. At that stage, following the progression of the WHOIS Accuracy Program, the customers’ names could potentially be suspended by the registrar if the customer does not update the contact information (either their own, or by signing up for a new PP service) to correct the inaccuracy. Is that the intended result? Best, Amy From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Carlton Samuels Sent: Tuesday, August 7, 2018 12:11 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Seems to me this is a simple case of caveat emptor! The P/P provider covenants that it has sold a service for which it is fully qualified to sell and provide, so far as that is required. The P/P customer accepts and covenants it has acquired the service in good faith and credit. P/P is not a baseline requirement pertaining stability and security of the DNS but an add-on choice. If the P/P provider turns out to be a scofflaw then the most that should happen is to take due care the P/P customer be given due notice that they bought a bill of goods and what is coming at them. And if they still need the conservation the service offers then they ought to go find another P/P service provider in good standing. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround ============================= On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> wrote: Thanks, Sara and Theo for your feedback on this. I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week. To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider. Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis). Thanks, all, and have a great weekend. Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes. Sara Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl<mailto:gtheo@xs4all.nl>] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Cc: Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
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> [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ 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
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 _______________________________________________ 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
Michele, Like I said, the licensor aka ICANN org/Compliance. They gave the stamp of approval saying the scofflaw was competent to provide the service. They accepted and ajudicated the complaint as non-complaint. They set the sanctions. They have the duty of care and must exercise the duty to care. -Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* ============================= On Tue, Aug 7, 2018 at 1:32 PM Michele Neylon - Blacknight < michele@blacknight.com> wrote:
Carlton
Sorry, but who is going to send this notice?
If the provider is in breach it’s probably because they haven’t been able to comply with contractual obligations.
Regards
Michele
--
Mr Michele Neylon
Blacknight Solutions
Hosting, Colocation & Domains
Intl. +353 (0) 59 9183072
Direct Dial: +353 (0)59 9183090
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow, R93 X265
,Ireland Company No.: 370845
*From: *Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Carlton Samuels <carlton.samuels@gmail.com> *Reply-To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org
*Date: *Tuesday 7 August 2018 at 19:14 *To: *"gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> *Subject: *Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Dear Amy:
What you have outlined is precisely what should happen.
The licensor - ICANN org - has a duty of care to the licensee's customer. That duty to care is exercised by good faith effort of the licensor to contact and update the licensee's customer from the moment the licensee - the P/P provider is adjudged to be in breach. There is a timeline for breach remediation. Assuming the breach is not mended, then the de-accreditation process kicks in.
In that communique to the P/P customer, the reasons will be outlined, the timeline for remediation and what will happen if not remediated; inaccurate WHOIS-RDS data which makes the domain name subject to suspension. That communique must outline the options available to that P/P customer if they wish to do to avoid that eventuality. I do not believe a registrar-marketing assist - which is what that bulk-transfer matter becomes for a favoured one is! - is ICANN's business.
It is done. Leave it to the registrant to act in their best interest.
-Carlton
============================== *Carlton A Samuels*
*Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround* =============================
On Tue, Aug 7, 2018 at 12:19 PM Amy Bivins <amy.bivins@icann.org> wrote:
Thanks, Carlton and all.
For those who recommend that ICANN org drop any reference to a bulk transition procedure from a terminating PP to a new PP, even if the registrar wants and agrees to facilitate this, how do you see this working for customers once the provider is terminated?
As the documents are drafted today, once a provider is terminated, the RDDS contact information is considered “inaccurate” for purposes of the registrar’s WHOIS accuracy program obligations under the RAA. At that stage, following the progression of the WHOIS Accuracy Program, the customers’ names could potentially be suspended by the registrar if the customer does not update the contact information (either their own, or by signing up for a new PP service) to correct the inaccuracy. Is that the intended result?
Best,
Amy
*From:* Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Carlton Samuels *Sent:* Tuesday, August 7, 2018 12:11 PM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Seems to me this is a simple case of caveat emptor! The P/P provider covenants that it has sold a service for which it is fully qualified to sell and provide, so far as that is required.
The P/P customer accepts and covenants it has acquired the service in good faith and credit.
P/P is not a baseline requirement pertaining stability and security of the DNS but an add-on choice. If the P/P provider turns out to be a scofflaw then the most that should happen is to *take due care* the P/P customer be given *due notice* that they bought a bill of goods and what is coming at them. And if they still need the conservation the service offers then they ought to go find another P/P service provider in good standing.
-Carlton
============================== *Carlton A Samuels*
*Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround* =============================
On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins <amy.bivins@icann.org> wrote:
Thanks, Sara and Theo for your feedback on this.
I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week.
To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider.
Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis).
Thanks, all, and have a great weekend.
Amy
-----Original Message----- From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review
Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes.
Sara
Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo <gtheo@xs4all.nl> wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" <gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl> wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto:gtheo@xs4all.nl] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins <amy.bivins@icann.org> Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1]
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw
ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T
plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A
vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ 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
Hi Carlton, They are all that you said, but, ICANN rarely do. I mean what you are suggesting is ICANN being a data controller - perish the thought ;p Kind regards, Chris From: "Carlton Samuels" <carlton.samuels@gmail.com> To: gdd-gnso-ppsai-impl@icann.org Sent: Tuesday, 7 August, 2018 20:27:45 Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Michele, Like I said, the licensor aka ICANN org/Compliance. They gave the stamp of approval saying the scofflaw was competent to provide the service. They accepted and ajudicated the complaint as non-complaint. They set the sanctions. They have the duty of care and must exercise the duty to care. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround ============================= On Tue, Aug 7, 2018 at 1:32 PM Michele Neylon - Blacknight < michele@blacknight.com > wrote: Carlton Sorry, but who is going to send this notice? If the provider is in breach it’s probably because they haven’t been able to comply with contractual obligations. Regards Michele -- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com https://blacknight.blog / http://ceo.hosting/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 ------------------------------- Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty Road,Graiguecullen,Carlow, R93 X265 ,Ireland Company No.: 370845 From: Gdd-gnso-ppsai-impl < gdd-gnso-ppsai-impl-bounces@icann.org > on behalf of Carlton Samuels < carlton.samuels@gmail.com > Reply-To: " gdd-gnso-ppsai-impl@icann.org " < gdd-gnso-ppsai-impl@icann.org > Date: Tuesday 7 August 2018 at 19:14 To: " gdd-gnso-ppsai-impl@icann.org " < gdd-gnso-ppsai-impl@icann.org > Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Dear Amy: What you have outlined is precisely what should happen. The licensor - ICANN org - has a duty of care to the licensee's customer. That duty to care is exercised by good faith effort of the licensor to contact and update the licensee's customer from the moment the licensee - the P/P provider is adjudged to be in breach. There is a timeline for breach remediation. Assuming the breach is not mended, then the de-accreditation process kicks in. In that communique to the P/P customer, the reasons will be outlined, the timeline for remediation and what will happen if not remediated; inaccurate WHOIS-RDS data which makes the domain name subject to suspension. That communique must outline the options available to that P/P customer if they wish to do to avoid that eventuality. I do not believe a registrar-marketing assist - which is what that bulk-transfer matter becomes for a favoured one is! - is ICANN's business. It is done. Leave it to the registrant to act in their best interest. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround ============================= On Tue, Aug 7, 2018 at 12:19 PM Amy Bivins < amy.bivins@icann.org > wrote: BQ_BEGIN Thanks, Carlton and all. For those who recommend that ICANN org drop any reference to a bulk transition procedure from a terminating PP to a new PP, even if the registrar wants and agrees to facilitate this, how do you see this working for customers once the provider is terminated? As the documents are drafted today, once a provider is terminated, the RDDS contact information is considered “inaccurate” for purposes of the registrar’s WHOIS accuracy program obligations under the RAA. At that stage, following the progression of the WHOIS Accuracy Program, the customers’ names could potentially be suspended by the registrar if the customer does not update the contact information (either their own, or by signing up for a new PP service) to correct the inaccuracy. Is that the intended result? Best, Amy From: Gdd-gnso-ppsai-impl [mailto: gdd-gnso-ppsai-impl-bounces@icann.org ] On Behalf Of Carlton Samuels Sent: Tuesday, August 7, 2018 12:11 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Seems to me this is a simple case of caveat emptor! The P/P provider covenants that it has sold a service for which it is fully qualified to sell and provide, so far as that is required. The P/P customer accepts and covenants it has acquired the service in good faith and credit. P/P is not a baseline requirement pertaining stability and security of the DNS but an add-on choice. If the P/P provider turns out to be a scofflaw then the most that should happen is to take due care the P/P customer be given due notice that they bought a bill of goods and what is coming at them. And if they still need the conservation the service offers then they ought to go find another P/P service provider in good standing. -Carlton ============================== Carlton A Samuels Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround ============================= On Fri, Aug 3, 2018 at 12:34 PM Amy Bivins < amy.bivins@icann.org > wrote: BQ_BEGIN Thanks, Sara and Theo for your feedback on this. I'm working on some proposed edits to this document based on your feedback--once I can discuss with Legal I'll have an updated draft for you. I hope to be able to send a draft to the list next week. To start, we're planning to change the word "transfer" to "transition" and to explicitly require coordination with the registrar as a necessary step for a bulk transition. We're also taking another look at notice requirements where a registrar is not involved in the facilitation of a bulk transfer, in which case a customer might need to transfer out if the customer wishes to transition to a new PP service provider. Theo, regarding your comments on the fees proposal, the activities listed as contributors to ongoing expected program costs (one of the 3 elements that fed into the proposed fees determination) were not itemized the way they were for the application phase (this would require a broader analysis). Thanks, all, and have a great weekend. Amy -----Original Message----- From: Gdd-gnso-ppsai-impl [mailto: gdd-gnso-ppsai-impl-bounces@icann.org ] On Behalf Of Sara Bockey Sent: Tuesday, July 31, 2018 8:31 AM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] [Ext] Re: Updated PP De-Accreditation Procedure Document Attached for IRT review Again. Agree with Theo. Use of the word “transfer” is confusing and problematic. We need to be able to reassign the service, contract with a new provider. Actual transfers would seem to be a dead last option. We don’t want to penalize the customer just because the P/P service changes. Sara Sent from my iPhone. Apologies for typos and/or brevity.
On Jul 31, 2018, at 1:39 AM, gtheo < gtheo@xs4all.nl > wrote:
I think the word transfer is somewhat confusing or does not meet the objective or can cause results that are not wanted.
I can imagine a reseller using privacy provider X. Privacy Provider X merges or hands over the business to Privacy Provider ABC.
The most logical path is that the reseller updates the domain names to the details of Privacy Provider ABC.
Transfering the domain names in bulk or through an inter-registrar transfer to the registrar of privacy provider ABC could be not wanted for various reasons. Reseller has to implement a new API with the new registrar. Billing issues. The new registrar may lack features key critical to the reseller at the current registrar. Etc the list is long.
A bulk transfer at a registry level, poorly communicated could create chaos.
Regarding the fees. The fee document seems to have two major components. Program Startup and Application Processing Here are all the costs listed.
Then there is the; Ongoing Accreditation Program Maintenance Here are no fees listed. Are the fees of the ongoing program maintenance listed in the program startup and application processing?
For example, Complaint processing is listed as ongoing. What are those costs? Or can I simply exclude them as those costs are not taken into account? How does that work? I think it is relevant as I expect complaint processing cannot be compared to the current situation in case of a registrar.
Thanks! Theo
Sara Bockey schreef op 2018-07-30 10:31 PM:
Apologies for weighing in late here, but I agree with Theo. I'm not understanding why the registrar would need to change per se. I also can imagine a scenario where a privacy provider (or registrar) reaches an agreement with another privacy provider to provide privacy. In fact, I think this would be the most likely option we would want - allow the registrar to contract with a new provider. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. On 7/26/18, 10:23 AM, "Gdd-gnso-ppsai-impl on behalf of Theo Geurts" < gdd-gnso-ppsai-impl-bounces@icann.org on behalf of gtheo@xs4all.nl > wrote: Hi Amy, If it is supposed to address both situations, isn't it somewhat odd a privacy provider can order a bulk transfer to another privacy provider at another registrar? I can imagine a scenario where a privacy provider reaches an agreement with another privacy provider to update all the domain names to one privacy provider. But to transfer domain names in bulk in the above scenario, does that benefit the registrant? I think it could create total chaos and disruption of services. Or is the above scenario unthinkable and am I chasing ghosts here? Thanks, Theo On 26-7-2018 15:03, Amy Bivins wrote:
Hi Theo,
Thanks for your feedback.
This was drafted to try to accommodate both types of situations, though, practically speaking, it seems probable that in most cases this would often involve an inter-registrar transfer.
There's nothing explicit in the document that would require obtaining consent from the registrar to a provider-provider bulk transfer under the same registrar. Do you (and others) think this should be an explicit requirement?
Best, Amy
-----Original Message----- From: gtheo [mailto: gtheo@xs4all.nl ] Sent: Thursday, July 26, 2018 4:54 AM To: gdd-gnso-ppsai-impl@icann.org Cc: Amy Bivins < amy.bivins@icann.org > Subject: [Ext] Re: [Gdd-gnso-ppsai-impl] Updated PP De-Accreditation Procedure Document Attached for IRT review
Hi Any, et al,
4.4 Voluntary Bulk Transfers, are we talking "transfers" from one privacy provider to another, or can a privacy provider request a transfer of all the domain names that are being used by a privacy provider at a registrar to another privacy provider at another registrar? I am somewhat struggling here with what we want to achieve and what a privacy provider can do here.
I think in all cases when a privacy provider requests a bulk transfer the sponsoring registrar has to agree also?
Thanks,
Theo
Amy Bivins schreef op 2018-07-25 03:37 PM:
Dear Colleagues,
Attached you will find a new draft of the PP De-accreditation and transition procedure, updated based on IRT feedback and our final (prior to public comment) internal review. If you have any further questions or comments on this document, please send them to the list.
We're nearly finished with the final editing/review process for the applicant guide and fees document, as well (there will be copy edits but no significant substantive changes). I'll send those to the list as soon as they are complete, likely before the end of this week.
Best,
Amy
AMY E. BIVINS
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org
www.icann.org [1]
Links: ------ [1] https://urldefense.proofpoint.com/v2/url?u=http-3A__www.icann.org&d=Dw ICAg&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=uerz4ckt1v4Qhbv-T plkjKTey9bgtdWrvLyZDu0mXuk&m=hoLHeBVkfOcUxl26F4OYnebcOzy-XUfRDXDSvGv8A vg&s=5TMUWmSpDbgeDaUkHtpmsyqhRhCEwWEKZSzPLqkJfwE&e= _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl _______________________________________________ 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 _______________________________________________ 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 BQ_END _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl BQ_END _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
participants (9)
-
Amy Bivins -
Carlton Samuels -
Chris Pelling -
Darcy Southwell -
gtheo -
Michele Neylon - Blacknight -
Sara Bockey -
Theo Geurts
-
Volker Greimann