Volker, hi - I tend to agree with Susan (and Lili). I believe it's important to make a recommendation with regard to accuracy of dada. That part of data is not going to be visible in the future (maybe even only for EU-data sets) makes it even more important to say that data must be accurate. There's no need to go further and to include obligations that are premature but ICANN must ensure that there's a clear understanding that accuracy is key. Kind regards, Erika On Thu, Jun 7, 2018 at 1:20 PM, Susan Kawaguchi <susankpolicy@gmail.com> wrote:
Hi Volker
I disagree that our only option is to say thank you. This recommendation is 6 years old so it would make sense that as an RT we would review the policy created by the PDP and make a recommendation in view of what has transpired in the last 6 years.
The Temp Spec addresses accuracy of data. What is being recommended is that a registrar treat the underlying registrant data the same way it is required to validate registrant data now. A registrar knows who their customer is and can ensure that the data under the PP is accurate without disclosing that to the world.
Your claim this would violate the underlying registrant's privacy I do not follow that line of thinking at all.
We should continue to discuss this recommendation.
Susan
On Thu, Jun 7, 2018 at 7:37 AM, Volker Greimann <vgreimann@key-systems.net
wrote:
I do not support any attempt to introduce an obligation for service providers to violate the privacy of their customers simply for purposes of "checks".
The PPSAI WG has made very specific decisions regarding the obligations of service providers regarding data quality. It is not our place to question these decisions which have been approved by the GNSO and the board and are now on their final stretch of implementation.
Our report should only say: "thank you ICANN, job well done!"
Anything beyond that is a job for the review of the policy after it has been implemented for a while.
Volker
Am 06.06.2018 um 20:21 schrieb Carlton Samuels:
Hi Lili: See my comments in line.
============================== *Carlton A Samuels*
*Mobile: 876-818-1799 Strategy, Process, Governance, Assessment & Turnaround* =============================
On Sat, Jun 2, 2018 at 10:21 PM, SUN Lili <L.SUN@interpol.int> wrote:
Dear Privacy & Proxy subgroup members,
I went through the draft report of this subgroup on wiki page ( https://community.icann.org/pages/viewpage.action?pageId=71604717) and step in with my concerns:
1. To the Data Accuracy subgroup, the Whois accuracy of domain names that utilize Privacy and Proxy Services is invisible. And Volker also mentioned that this will be dealt with in the Privacy & Proxy subgroup.
Under current rules, the accredited P/P provider is obliged to ensure contactability of customer of his service. That this is the case cannot be verified independently and some of us have argued from inception this is a major hole in the agreement. We have alternately argued that there should be graded penalties for this violation after the fact.
As such, I strongly support Susan’s comments on “6 Conducting periodic due diligence checks on customer contact information” and “8 Providing clear and unambiguous guidance on the rights and responsibilities of registered name holders, and how those should be managed in the privacy/proxy environment.” There is no reason for a customer who chose P/P service thus been protected from responsibilities.
See above. We expect that the risk triage will allow the cost of violation to pass to the customer.
2. There is no indication about the legacy domain names that utilize P/P Services before the provider been accredited. Will it be a similar situation as Grandfathered domains?
Some of us have argued that there should be a Privacy/Proxy Data Accuracy Reminder policy along the line of the WHOIS Data reminder. It was not accepted. But there is no reason the P/P provider cannot be obliged and bound to it in terms of the accreditation for renewals.
3. Like the example I gave during the 2nd F2F meeting, if there is not enough regulation and overseeing in place, P/P service is very likely to be abused. To be clear, I elaborated the example in a word document (see attached). Do we really need this kind of fake prosperity of domain industry?
A response from this subgroup is much appreciated.
Best, -Carlton
Thanks,
Lili
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