Hi Steve, If there is anyone (including law enforcement), who thinks that a registrar does not have proper contact information available, then they should immediately file a complaint with ICANN Contractual Compliance. The RAA has a number of contact obligations for registrars, and speaking from experience, Compliance can and will send breach notices to registrars for not providing the required contact information. Regards, Owen
On Jul 18, 2023, at 12:56, Steve Crocker via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
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Rubens,
Thanks. I’ve been told the registrars want to avoid being bedeviled with bulk and/or bogus requests. I’ve also been told that at least some law enforcement personnel don’t believe there is contact information available for all registrars.
Steve
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On Jul 18, 2023, at 3:50 PM, Rubens Kuhl via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> wrote:
Em 18 de jul. de 2023, à(s) 16:05, Steve Crocker via IRT.RegDataPolicy <irt.regdatapolicy@icann.org> escreveu:
Sarah,
What’s missing from the language you’re referring to is a way to contact the registrar on an urgent basis.
That’s already baked in 10.1:
10. Disclosure Requests 10.1. Registrar and Registry Operator MUST publish on their homepage a direct link to a page where the mechanism and process for submitting Disclosure Requests is detailed. The mechanism and process MUST specify (a) the required format and content of requests, (b) the Registrar’s or Registry Operator’s means of providing a response to the requestor, and (c) the anticipated timeline for responses
So in order to fulfill (c) above for urgent requests, (a) and (b) also need to address how an urgent request differs from the other requests on how to perform one and how one is handled.
One sample implementation could be:
“For standard disclosure requests, this-and-this-and-that requirements, please click here. For urgent requests, which would need the requirements above plus this other criteria, please call 1-800-REG-DATA”
Rubens
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