Data escrow question WAS RE: Action Items From Today's PP IRT Call
With the hope of jump-starting a bit the data escrow discussion that is teed up for Tuesday, let me share with the list the question I raised on this morning's brief attempted call of the subteam re unaffiliated providers. The data escrow provisions in the draft accreditation agreement are quite complex and detailed, amounting to a 5-page specification. We are told this specification is drawn from the standard gTLD registry agreement. By contrast, the data escrow obligations in the Registrar Accreditation Agreement are boiled down to a single paragraph (section 3.6). Since all the p/p providers that have engaged in the WG and in the IRT are affiliated with accredited registrars, we have sought to maximize the situations in which these providers may be able to "piggy-back" on obligations already undertaken by registrars, in order to minimize unnecessary duplication of effort. Data escrow would appear to be an excellent candidate for this treatment as well. Perhaps RAA section 3.6 could be adapted for the p/p accreditation context. (Of course, if the RAA provision is modified in the future to align more closely with the registry obligations, the p/p obligations may be able to move in lockstep with it.) Of course this is not a complete solution, we would still have to look at the obligations for unaffiliated providers, but at least for the affiliated ones this seems more efficient. So my question is, what is the downside of this approach? Put another way, what would be the advantage gained by aligning the p/p escrow obligations with those of registries, rather than those of registrars? Amy perhaps you can also pass this question on to the ICANN technical staff that will be on Tuesday's call, so that they can respond to it on this list, or if not, on Tuesday's call. Thanks all and have a good weekend. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, July 18, 2017 11:36 AM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: * Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached). 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 Steve, et al, I guess due to section 3.6 in the RAA being more than a decade old the Registry requirements might be perceived as overkill? Most Escrow providers already demand most of the things described in the Registry requirements. For example validation of the signature file. Other parts of the requirements are common sense. 2048 Bit Encryption, bare minimum requirement, if there are Escrow Agents out there who accept less than 2048, they shouldn't be even an Escrow Agent in my opinion. Full deposits and differential deposits. You don't want missing data, that is why most companies use a differential backup for their data. Minimize risk. In short, it is nice to see most of the stuff listed in a section and being up to date! But most of it is not new for Registrars, and as a contracted party I have no issue with it. What is missing in this specification is that the non-affiliated privacy provider should specify at which registrar the domain name is, they provide privacy services for in the deposit. For Registrars or affiliated privacy services, this is a nonissue as anything at a different Registrar is no longer provided by those Registrars or affiliated providers as a service. Best regards, Theo Geurts On 21-7-2017 22:07, Metalitz, Steven wrote:
With the hope of jump-starting a bit the data escrow discussion that is teed up for Tuesday, let me share with the list the question I raised on this morning’s brief attempted call of the subteam re unaffiliated providers.
The data escrow provisions in the draft accreditation agreement are quite complex and detailed, amounting to a 5-page specification. We are told this specification is drawn from the standard gTLD registry agreement. By contrast, the data escrow obligations in the Registrar Accreditation Agreement are boiled down to a single paragraph (section 3.6).
Since all the p/p providers that have engaged in the WG and in the IRT are affiliated with accredited registrars, we have sought to maximize the situations in which these providers may be able to “piggy-back” on obligations already undertaken by registrars, in order to minimize unnecessary duplication of effort. Data escrow would appear to be an excellent candidate for this treatment as well. Perhaps RAA section 3.6 could be adapted for the p/p accreditation context. (Of course, if the RAA provision is modified in the future to align more closely with the registry obligations, the p/p obligations may be able to move in lockstep with it.)
Of course this is not a complete solution, we would still have to look at the obligations for unaffiliated providers, but at least for the affiliated ones this seems more efficient. So my question is, what is the downside of this approach? Put another way, what would be the advantage gained by aligning the p/p escrow obligations with those of registries, rather than those of registrars?
Amy perhaps you can also pass this question on to the ICANN technical staff that will be on Tuesday’s call, so that they can respond to it on this list, or if not, on Tuesday’s call.
Thanks all and have a good weekend.
Steve Metalitz
*image001*
*Steven J. Metalitz *|***Partner, through his professional corporation*
T: 202.355.7902 |met@msk.com <mailto:met@msk.com>**
*Mitchell Silberberg & Knupp**LLP*|*www.msk.com <http://www.msk.com/>*
1818 N Street NW, 8th Floor, Washington, DC 20036
*_THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS._**THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.*
*From:*gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] *On Behalf Of *Amy Bivins *Sent:* Tuesday, July 18, 2017 11:36 AM *To:* gdd-gnso-ppsai-impl@icann.org *Subject:* [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call
Hi, All,
Thanks so much for your attendance at the PP IRT call today.
As mentioned, next week, we plan to discuss:
1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week)
*IRT Action Items*
1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: 1. Any over-arching comments you have on the specification; 2. How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar’s deposits. Given that registrars are on a different specification, this raises a potential issue; 3. Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA “issues list” and be prepared to discuss the IRT’s prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks.
For your info, I’m also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I’m searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it.
If you have questions or comments, please don’t hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the “suggested modification” form (attached).
Best,
Amy
*Amy E. Bivins*
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax: +1 (202) 789-0104
Email: amy.bivins@icann.org <mailto:amy.bivins@icann.org>
www.icann.org <http://www.icann.org>
_______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Hi Steve, I remember the F2F in Dublin - it was agreed that any third party provider would have to do the same as a registrar. Theo has highlighted those parts, but, ultimately we have to have the same standards for the escrow service to accept the data, whether that be for the registrar or third party provider. I'll also mention that I am sure the current escrow services will not change the way they currently accept data, nor process it for ICANN compliance. Kind regards, Chris From: "Steven Metalitz" <met@msk.com> To: gdd-gnso-ppsai-impl@icann.org Sent: Friday, 21 July, 2017 21:07:04 Subject: [Gdd-gnso-ppsai-impl] Data escrow question WAS RE: Action Items From Today's PP IRT Call With the hope of jump-starting a bit the data escrow discussion that is teed up for Tuesday, let me share with the list the question I raised on this morning’s brief attempted call of the subteam re unaffiliated providers. The data escrow provisions in the draft accreditation agreement are quite complex and detailed, amounting to a 5-page specification. We are told this specification is drawn from the standard gTLD registry agreement. By contrast, the data escrow obligations in the Registrar Accreditation Agreement are boiled down to a single paragraph (section 3.6). Since all the p/p providers that have engaged in the WG and in the IRT are affiliated with accredited registrars, we have sought to maximize the situations in which these providers may be able to “piggy-back” on obligations already undertaken by registrars, in order to minimize unnecessary duplication of effort. Data escrow would appear to be an excellent candidate for this treatment as well. Perhaps RAA section 3.6 could be adapted for the p/p accreditation context. (Of course, if the RAA provision is modified in the future to align more closely with the registry obligations, the p/p obligations may be able to move in lockstep with it.) Of course this is not a complete solution, we would still have to look at the obligations for unaffiliated providers, but at least for the affiliated ones this seems more efficient. So my question is, what is the downside of this approach? Put another way, what would be the advantage gained by aligning the p/p escrow obligations with those of registries, rather than those of registrars? Amy perhaps you can also pass this question on to the ICANN technical staff that will be on Tuesday’s call, so that they can respond to it on this list, or if not, on Tuesday’s call. Thanks all and have a good weekend. Steve Metalitz Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met@msk.com Mitchell Silberberg & Knupp LLP | www.msk.com 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, July 18, 2017 11:36 AM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: 1. Any over-arching comments you have on the specification; 2. How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar’s deposits. Given that registrars are on a different specification, this raises a potential issue; 3. Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA “issues list” and be prepared to discuss the IRT’s prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I’m also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I’m searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don’t hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the “suggested modification” form (attached). 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 _______________________________________________ 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, Steve. I'll forward this question to the tech services team to ensure we can discuss it tomorrow. From: gdd-gnso-ppsai-impl-bounces@icann.org [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Metalitz, Steven Sent: Friday, July 21, 2017 4:07 PM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] Data escrow question WAS RE: Action Items From Today's PP IRT Call With the hope of jump-starting a bit the data escrow discussion that is teed up for Tuesday, let me share with the list the question I raised on this morning's brief attempted call of the subteam re unaffiliated providers. The data escrow provisions in the draft accreditation agreement are quite complex and detailed, amounting to a 5-page specification. We are told this specification is drawn from the standard gTLD registry agreement. By contrast, the data escrow obligations in the Registrar Accreditation Agreement are boiled down to a single paragraph (section 3.6). Since all the p/p providers that have engaged in the WG and in the IRT are affiliated with accredited registrars, we have sought to maximize the situations in which these providers may be able to "piggy-back" on obligations already undertaken by registrars, in order to minimize unnecessary duplication of effort. Data escrow would appear to be an excellent candidate for this treatment as well. Perhaps RAA section 3.6 could be adapted for the p/p accreditation context. (Of course, if the RAA provision is modified in the future to align more closely with the registry obligations, the p/p obligations may be able to move in lockstep with it.) Of course this is not a complete solution, we would still have to look at the obligations for unaffiliated providers, but at least for the affiliated ones this seems more efficient. So my question is, what is the downside of this approach? Put another way, what would be the advantage gained by aligning the p/p escrow obligations with those of registries, rather than those of registrars? Amy perhaps you can also pass this question on to the ICANN technical staff that will be on Tuesday's call, so that they can respond to it on this list, or if not, on Tuesday's call. Thanks all and have a good weekend. Steve Metalitz [image001] Steven J. Metalitz | Partner, through his professional corporation T: 202.355.7902 | met@msk.com<mailto:met@msk.com> Mitchell Silberberg & Knupp LLP | www.msk.com<http://www.msk.com/> 1818 N Street NW, 8th Floor, Washington, DC 20036 THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS. THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU. From: gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org> [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Amy Bivins Sent: Tuesday, July 18, 2017 11:36 AM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] Action Items From Today's PP IRT Call Hi, All, Thanks so much for your attendance at the PP IRT call today. As mentioned, next week, we plan to discuss: 1. The data escrow specification in the draft PPAA (attached); 2. IRT prioritization of issues from issues list (attached, updated as of most recent communication this morning from PSWG); 3. (Possibly) PPAA amendment process (will confirm by end of this week) IRT Action Items 1. Review the draft data escrow specification and come to 25 July meeting prepared to discuss: * Any over-arching comments you have on the specification; * How this specification should be applied to Registrar-affiliated Providers. Prior IRT input was that affiliates should be able to satisfy escrow requirements through the registrar's deposits. Given that registrars are on a different specification, this raises a potential issue; * Any thoughts about how use of this specification might impact/mitigate concerns that have been raised about third-party providers. 2. Review the PPAA "issues list" and be prepared to discuss the IRT's prioritization of issues for discussion. The goal of this discussion is to map out a discussion schedule, by topic, for at least the next several weeks. For your info, I'm also attaching the most recent of the Policy document and the Applicant Guide (both of which are referenced in the Final Recommendations mapping document and will be revisited by the IRT in the coming weeks/months. ICANN is currently updating the Applicant Guide per IRT feedback and will be distributing to the IRT for review in the coming months (significant changes expected in the Application section). I'm searching for the communication about the Transfer Policy work that could be added to this IRT and will send to the list when I locate it. If you have questions or comments, please don't hesitate to share them with the list. If you have specific suggestions for edits to the PPAA draft, please submit the "suggested modification" form (attached). 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>
participants (4)
-
Amy Bivins -
Chris Pelling -
Metalitz, Steven -
theo geurts