Hi Steve,

I would think that we are tracking this statistic by using the "already public" option. 

The only other circumstance where "already public" is applicable is when the registrant has opted to publish their registration data, in which case there's no reason to submit an RDRS request, so there should be a vanishingly small number of those requests (if any).

Thanks,

Sebastian,

Thanks for this update and thanks to Sarah Wyld, John McElwaine and you for the additional effort.

Your point about Privacy and Proxy being out of scope is clear and understood.  That said, this issue is likely to greatly skew the statistics.  When a requestor fails to get the needed data because it's hidden behind a privacy or proxy provider, the registrar is likely to count this as a successful transaction in the sense that it conforms to the rules, but the requestor is likely to count it as a failure.

When the dust settles and it's time to evaluate whether the RDRS has been a successful experiment and whether we should or should not move forward with a fuller system akin to the SSAD, we might find ourselves with strongly divergent opinions.

I think we would be best served by distinguishing responses that are technically correct within the specifications of the RDRS experiment but are nonetheless unsatisfactory for the requestors.  It would be but a small but important improvement in the reporting to keep track of this statistic.

Thanks,

Steve

On Thu, Mar 14, 2024 at 10:55 AM Sebastien@registry.godaddy <Sebastien@registry.godaddy> wrote:

Dear Standing Committee and ICANN Colleagues,

 

Sarah Wyld, John McElwaine and I had a call today to review the issue of responses to Privacy and Proxy.

It transpired during the ICANN79 week, on and off mic, that a substantial part of the denials received by Requestors were due to PP, but were not captured in a consistent manner across all responding Registrars.
The Standing Committee is not going to resolve the issue of PP; there is a bespoke group looking into it and currently working next steps out between Staff and Council. The SC obviously should not influence Registrars’ balancing test and decisions around disclosure. This said, we agreed that efforts are required into ensure that same outcomes should be returned to the Requestors via the system in same statistically trackable answers.

 

We agree and submit to the Committee that:

1. The gamut of existing available answers exists on the current platform, there is no need to add any PP specific answer. If the registrar is aware that the domain uses a P/P service and will not disclose any further data, they should use the checkbox labelled "If all of the data is publicly available, please check this box" .
2. Requestor FAQ/User Guide should be adapted to clearly indicate that “all data is publicly available” typically refers to a registration under PP which the Registrar is unable to disclose and for which disclosure should be requested directly from the PP provider.
3. Registrar FAQ/User Guide should be adapted to clearly indicate that the “If all of the data is publicly available, please check this box” checkbox should be used in the case of data Requests under known PP which a Registrar cannot disclose directly.
4. In-line tips in the Registrar interface should be added (pop-up additional information, or directly in-line) as a reminder to the same. This is redundant information, but we see it as important to ensure existing Registrars who are not likely to regularly consult the FAQs, be aware of this new guideline.
5. Communicate on the same with Requestor and Registrar communities via already established channels.

 

We look to Staff for help and guidance for items 2, 3 and 4.
5 should be relayed to ICANN Account Managers in charge of participating Registrars.

 

This will neither resolve the issue of PP nor change the level of data disclosure, but aims at:

• Offering a clearer answer to requestors, and limit the diversity of answers given to a same issue,
• Allowing to more clearly track Requests under PP and avoid having them weighing on disclosure/non-disclosure statistics.

 

We look forward to your comments.

 

Kindly,

 

 

Sebastien Ducos

GoDaddy Registry | Senior Client Services Manager

+33612284445

France & Australia

sebastien@registry.godaddy

 

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