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(red star)Objective

Consistent with ICANN’s mission and Bylaws, Section 4.6(e)(iv), the Review Team will (a) evaluate the extent to which ICANN Org has implemented each prior Directory Service Review recommendation (noting differences if any between recommended and implemented steps), (b) assess to the degree practical the extent to which implementation of each recommendation was effective in addressing the issue identified by the prior RT or generated additional information useful to management and evolution of WHOIS (RDS), and (c) determine if any specific measurable steps should be recommended to enhance results achieved through the prior RT’s recommendations. This includes developing a framework to measure and assess the effectiveness of recommendations, and applying that approach to all areas of WHOIS originally assessed by the prior RT (as applicable). 

RT1 Recommendations to be assessed by this subgroup:

Recommendation #10 - Privacy/Proxy Services

Background Documents

Further background documents may be found on the Review Team's overall Background Materials page.

(red star)Leader/Rapporteur: Volker Greimann

(red star)Members: Cathrin Bauer-Bulst, Stephanie Perrin, Susan Kawaguchi, Volker Greimann, Dmitry Belyavsky

(red star)Mailing-list archives: http://mm.icann.org/pipermail/rds-whois2-privacy-proxy/

(red star)Conference calls: see here

(red star)Review Team Templates: see here


Subgroup Documents


DOCX

Date

Document (Versions in Red are latest)

File

Subgroup Report

v9DOCX

 

v8DOCX

 

v7 (incl. FtoF #3 Agreements)DOCX

 

v6DOCX

 

v5DOCX

 

v4DOCX

 

v3

DOCX

 

v2DOCX

v1DOCX
Face-to-Face Mtg #2 Slides - Findings

 

v2PPTX

 

v1PPTX

Case Study of P&P Service Abuse (submitted by Lili)

 

v1DOCX
Planning Questions

 

v1PDF
First Pass Document

 

v4DOCX
 v3DOCX

 

v2DOCX

 

v1DOCX

ICANN Org Briefings/Answers

Open Actions/Requests

Item #Source of RequestDate of RequestAction Item RequestAction Owner

Anticipated Completion Date*

Progress Notes

Completed Actions/Requests

*To be provided once reasonable date is determined by appropriate subject-matter expert

Item #Source of RequestDate of RequestAction Item RequestAction Owner

Anticipated Completion Date*

Progress NotesCompleted ResponseCompletion Date
19#37

 

Apply editorial change "The ICANN Board should recommend to the next review team" to rec 10.2 (also 12.1)

ICANN org


 

18FtoF #3

Volker to update subgroup report to reflect decisions reached and proposed recommendation.Volker


 

17#34

Volker to address any concerns raised in a final draft to be sent to the full RT by the end of this week.Volker


 

16#34

 

Subgroup members to take a last look at the subgroup report and submit comments via email or confirm they agree with the subgroup draft report as is.Subgroup



15#3

 

Volker to propose text for an issue on Abuse noting that PP abuse may occur and that a future review should include examining the impact of PP services on abuse. Consider whether this should lead to a recommendation that this be examined within 2 years after implementation/effective date of the policy - and/or collection of data to enable review.Volker

Email

 

14#3

 

Volker to reword Issue #2 (impact of GDPR) to clarify comment but make no recommendationVolker

Email

 

13#3

 

Volker to reword Issue #1 (cost/fees) as a brief comment but not a recommendation, since implementation is underway and it is not yet time to make any recommendation on thisVolker

Email

 

12#3

 

Additional issue related to grandfathering:

(a) Volker to draft language regarding accuracy trigger in 2013 RAA for consideration by RT when data accuracy report is discussed (this will not to be addressed in PP report as "grandfathering" does not apply to PP registered domains)

(b) Susan to revise Recommendation on grandfathering compliance in the Compliance Subgroup report to broaden it to include all policies and DN registrations

Volker/Susan

Email

 

11#3

 

Volker to provide alternative text for Rec 10 Objective 6 referring to PPSAI PDP recommendation on CATEGORY B QUESTION 2, indicating this objective was taken into consideration in the PDP but it is not appropriate for the RT to comment on sufficiency of this until implementation is complete.

The PPSAI PDP recommendation:

WG Conclusion: The WG recommends that P/P service customer data be validated and verified in a manner consistent with the requirements outlined in the WHOIS Accuracy Program Specification of the 2013 RAA (as updated from time to time). Moreover, in the cases where a P/P service provider is Affiliated with a registrar and that Affiliated registrar has carried out validation and verification of the P/P customer data, re-verification by the P/P service provider of the same, identical, information should not be required.

Volker

Email

 

10#28

 

ICANN org to prepare and send out doodle for a subgroup meeting (incl. Stephanie) this week, based on Volker's availability.

ICANN org

Email

 

9#27

 

Susan to liaise with Volker and progress on the subgroup draft report.

Susan

Email

 

7#26

 

Volker to clarify following issues for RT:

  • Issue #1: Current funding proposals for accreditation program create concerns of ICANN failing the goal of onboarding all providers of such services due to inflation of costs. ICANN Org staff seems to be unable to justify proposed accreditation fees, which may endanger the entire program.
  • Issue #2: Impact of GDPR data redaction requirements on privacy services are yet unknown, but significant impact is expected as personal data becomes hidden by default without 
Volker

Email

 

8

#26

 

Dmitry to be added to Rec #10: Privacy/Proxy ServicesICANN org



6#25

 

Susan to touch base with Volker on subgroup reportSusan

Email

 

5#22

Susan to review list of questions in light of Alan's comments https://mm.icann.org/pipermail/rds-whois2-privacy-proxy/2018-March/000016.htmlSusan/
Email

 

3#1

 

Schedule briefing with ICANN Org staff leading the IRT staff support to learn how team will ramp up to manage PPSAI policy compliance.ICANN org

 


Email

 

4#1

Request written briefing from ICANN Org if there are complaints that have been filed related to 2013 RAA specs, if so what was the nature of those complaints and steps taken.Subgroup members

 


Email

 

2#1

 

Provide first draft of questions for IRT compliance team (by 27 Feb).Susan

 


Email

 

1#1

 

Draft answers to planning questions and provide to Volker to review and share with subgroup.ICANN org

 


/

Decisions Reached

Source of requestDateDecision
FtoF #3

 

R10.x to be added to P/P section: R10.x  Reviewing the effectiveness of the implementation of #Rec 10 should be deferred and carried out by the next RDS review team after PPSAI Policy is implemented.

FtoF #3

 

Issue #5 to be expanded to discuss P/P abuse risk, potential for change in P/P use due to GDPR, a reference to the WHOIS P/P Abuse Study, and also to the CCT RT study on P/P and DDARP recommendation (when available).

FtoF #3

 

Issue #3 is subject to confirmation after ICANN legal review is completed: The RT is currently not aware of any need to delay the implementation of accreditation program due to GDPR.

FtoF #3

 

The entire P/P Issues/Problems section should be prefaced with a qualifier that the issues are based on the status of PPSAI policy implementation as of July 2018, and are subject to update as implementation continues.

FtoF #3

 

No change to subgroup’s conclusion that the recommendation to initiate policy development is “fully implemented” but the conclusion should clearly state that policy implementation remains underway.

#3

 

The subgroup will follow the RT's agreement to not relegislate PDPs. Can raise concerns but should not make recommendations to modify PDP WG's recommendations prior to implementation.

#3

 

Grandfathering is not a concept for PP registered domains but should be taken up in the data accuracy and compliance reports
#1

 

All subgroups members are to review PPSAI and RAA specs on Privacy/Proxy.

#1

 

Subgroup to review implementation of RT1 recommendation: 2013 RAA specs and PPSAI policies. IRT is underway to policy effective date is unlikely to be this year. Limit subgroup's work to what has been completed and not wait for policy to become effective. 

#1

 

Subgroup to develop questions for IRT Compliance team.

#1

 

Rapporteur will collate the findings of all members into a single document. All subgroup members to review/contribute to findings.