Dear EPDP Team: Further to EPDP Support Staff’s action item to follow up with ICANN org re: the Clarification on display of information of affiliated vs. accredited P/P providers, please see the below response from ICANN org. Thank you. Best regards, Marika, Berry, and Caitlin From: Cyrus Jamnejad <cyrus.jamnejad@icann.org> Date: Tuesday, December 3, 2019 at 12:49 PM To: Caitlin Tubergen <caitlin.tubergen@icann.org> Cc: Marika Konings <marika.konings@icann.org>, "policy@bacinblack.com" <policy@bacinblack.com>, Karen Lentz <karen.lentz@icann.org>, Amanda Fessenden <amanda.fessenden@icann.org> Subject: Re: Clarification on display of information of affiliated vs. accredited P/P providers Hi Team, Thanks for reaching out, and my apologies on the delayed response. I hope I haven’t set you back, and I am happy to discuss further if you’d like to. I want to also thank Amy Bivins for her amazing help on this. So your request references two recommendations, EPDP Phase 1 Recommendation 14 (and its accompanying note), and PPSAI Recommendation 4. In asking, “Can you please provide clarifying information on how this recommendation is being implemented?” I understand you to be asking about PPSAI Recommendation 4. The EPDP Phase 1 IRT is in the process of implementing EPDP Phase 1, Recommendation 14. As you are aware, the PPSAI implementation (and IRT) is on hold pending the resolution of the EPDP Phase 2 work. There is no current activity underway. In term of the implementation of PPSAI Recommendation 4, the PP IRT was considering a proposed requirement that all privacy and proxy service providers include a label, which would flag each registration as a privacy/proxy registration and identify which provider is associated with that registration, in the existing WHOIS output “registrant organization” field. (See Draft PPAA, distributed to PP IRT 12 Sept 2018, at https://mm.icann.org/pipermail/gdd-gnso-ppsai-impl/attachments/20180913/4267..., Section 3.15). This requirement would apply to all privacy and proxy service providers, regardless of whether the provider is affiliated with a registrar or registry operator or operating independently of any other contracted party. The draft privacy and proxy service provider accreditation agreement does not distinguish between requirements for registrar-affiliated and non-affiliated privacy and proxy service providers, at the direction of the PPSAI IRT. The draft requirements would require all privacy and proxy service providers to become accredited to continue offering those services. This requirement for accreditation would be enforced through the registrar, on the grounds that accredited registrars could not knowingly accept registrations involving a privacy or proxy service from an unaccredited provider (See PPSAI recommendation 1, note, p. 7, https://gnso.icann.org/sites/default/files/filefield_48305/ppsai-final-07dec...). Following the completion of the EPDP Phase 2 work and the Rec 27 analysis, the existing draft PPSAI materials will need to be revisited to ensure consistency with the EPDP-recommended requirements, and to ensure the requirements and processes fit together in a manner that will create a transparent, predictable, and reasonable process for all parties involved. I hope this helps, and again, please reach out if more is needed. Best, Cyrus Jamnejad gTLD Accounts & Services Manager Internet Corporation for Assigned Names and Numbers (ICANN) Skype: cyrus.jamnejad.icann Telephone: +1 310 578 8635 www.icann.org From: Caitlin Tubergen <caitlin.tubergen@icann.org> Date: Wednesday, October 30, 2019 at 8:50 AM To: Cyrus Jamnejad <cyrus.jamnejad@icann.org> Cc: Marika Konings <marika.konings@icann.org>, "policy@bacinblack.com" <policy@bacinblack.com>, Karen Lentz <karen.lentz@icann.org> Subject: Clarification on display of information of affiliated vs. accredited P/P providers Dear Cyrus: On behalf of the EPDP on the Temporary Specification for gTLD Registration Phase 2 Team, we are writing to request clarification on the display of information of affiliated vs. accredited privacy/proxy providers within the context of the implementation of the Privacy and Proxy Services Accreditation Issues Working Group’s recommendations. As part its work in Phase 1, the EPDP Team made the following recommendation in its Final Report: “In the case of a domain name registration where an ‘affiliated’ privacy/proxy service used (e.g., where data associated with a natural person is masked), Registrar (and Registry where applicable) MUST include in the public RDDS and return in response to any query full non-personal RDDS data of the privacy/proxy service, which MAY also include the existing privacy/proxy pseudonymized email.” The EPDP Team went on to note, “PPSAI is an approved policy that is currently going through implementation. It will be important to understand the interplay between the display of information of affiliated vs. accredited privacy / proxy providers. Based on feedback received on this topic from the PPSAI IRT, the EPDP Team may consider this further in phase 2”. As you are aware, the Privacy and Proxy Services Accreditation Issues Working Group recommended the following, “[t]o the extent that this is feasible, domain name registrations involving P/P service providers should be clearly labelled as such in WHOIS.” Can you please provide clarifying information on how this recommendation is being implemented? Thank you. Best regards, Marika, Berry, and Caitlin EPDP Policy Development Support Staff