Hello All, After a meeting by the subgroup on Friday I have made revisions to the subgroup report for discussion during our call on Monday. - Rec#1 - revise to read "enforced as required" to address Stephanie's comment on F2F#2 - Rec#4 - incorporate into Outreach report existing recommendation 3.2 as a specific example of desired outreach, and refer to the Outreach recommendation from Section 3.2.1.2 in Compliance report - Rec #5 - expand recommendation text to focus on compliance processes to encourage use of Bulk tool, - Rec #8 - refer to Bulk WHOIS tool when discussing possible sources of input to identify systemic abuse - Rec#7 - discuss clarified text for this Recommendation in plenary - To address Accuracy issue where accuracy of P/P registration data is not monitored and cannot be enforced, draft a new recommendation that P/P registration data providers must adhere to the current RAA requirements for verification and validation. - Raise as comments on Rec #11 subgroup report (Common Interface) for discussion in plenary call: (1) As a result of GDPR implementation, RR and Ry interpretations may result in different registration data returned by WHOIS for the same domain name (e.g., the Ry may redact data that the RR displays) (2) Bulk data access has become less reliable (e.g., timeouts more frequent) I also started a draft recommendation on accuracy in PP registrations *Privacy and Proxy registration data providers must adhere to the current RAA requirements for verification and validation of the underlying registrant data. * The following is from the PPSAI final report, I thought it may help in the discussion. P/P service providers should be required to inform the P/P service customer annually of his/her requirement to provide accurate and up to date contact information to the P/P service provider. If the P/P service provider has any information suggesting that the P/P service customer information is incorrect (such as the provider receiving a bounced email notification or non-delivery notification message in connection with compliance with data reminder notices or otherwise) for any P/P service customer, the provider must verify or re-verify, as applicable, the email address(es). If, within fifteen (15) calendar days after receiving any such information, the P/P service provider does not receive an affirmative response from the P/P service customer providing the required verification, the P/P service provider shall verify the applicable contact information manually. Susan