Re: [gnso-raa-b] RAA: topics in category #6: proxy/privacy registration services
- To: "Metalitz, Steven" <met@xxxxxxx>
- Subject: Re: [gnso-raa-b] RAA: topics in category #6: proxy/privacy registration services
- From: Holly Raiche <h.raiche@xxxxxxxxxxxxxxxx>
- Date: Sat, 2 Jan 2010 17:12:18 +1100
Hi Steven (and Everyone)
First, a recommendation that we start with ICANN's study on 'the
prevalence of Domain Names Registered using a privacy or proxy server
among the top 5 gTLDs'. This document really just outlines the work
they will do in future on the study, but sets out definitions we
should use for this topic:
A privacy service provider offers the registrant an opportunity to
register a domain name while concealing some personal identifying
information listed in a WHOIS directory, such as his or her address,
telephone number, or email address, by providing alternate contact
information, often that of the privacy service provider.
A proxy service provider registers the domain name on the
registrant’s behalf and then licenses the use of the domain name to
the registrant. The contact information in a WHOIS directory for a
domain name registered with a proxy service is that of the proxy
Next, the preliminary findings are that around 25% of domain names
use a privacy or proxy service provider.
My other comments are interspersed:
Internet Society of Australia (ISOC-AU)
Mob: 0412 688 544
Ph: (02) 9436 2149
The Internet is For Everyone
Do we want to distinguish between privacy and proxy services, as set
out above? There may be a number of legitimate reasons why a
registrant may not want personal details made public - which may not
be the case with proxy services. Or, alternatively, should we not
distinguish between the two?
RAA subteam B participants:
As discussed on our most recent call, in order to move our work
forward, it was recommended that we launch discussion of some of
the remaining categories in the compiled list of RAA amendment
topics. (I am using the revised chart, posted earlier today and
dated today, December 30.)
According to my notes, we have discussed topics 1-4 in our previous
call. On topic 5 -- compliance -- I have, by a message posted
earlier today, asked staff to provide their views on our next call
on Tuesday, Jan. 5. So this phase will begin with topic #6.
Here are some views put forward to get the discussion started,
recognizing that our role at this stage is primarily to organize
and prioritize the topics proposed, rather than to delve too deeply
into the details of the proposals made. (This does not preclude us
from deciding, if we can, that one or another topic is simply out
of scope or not appropriate for consideration with regard to RAA
RE: Topics in category #6
This category includes many topics related to proxy/privacy
registration services. I suggest that another item belongs here as
well: item 8.4, re such services provided by resellers.
A number of these items can be grouped in subcategories as follows:
A. Escrow and data collection/preservation: items 6.1 and 6.7.
B. Obligations/disclosures of registrars regarding services they
(or resellers) operate or make available in connection with
registration: items 6.2, 6.4, 6.8(B), 8.4.
I would support the mandatory escrow of registrant data, with
discussion to follow on circumstances under which such data is
revealed. 22.214.171.124 notes the discussion needed on what is meant by
actionable harm and malicious conduct - so I agree this will take
longer to deal with . Note the amended RAA gives the option of
registrar's simply displaying a notice to customers that their data
is not being escrowed -which we are now considering changing before
it is even fully implemented.
Again, should this refer to both privacy and proxy services, or only
C. RELAY function of services: item 6.3.
D. REVEAL function of services: item 6.5, 6.6, 6.10.
All these subcategories should be considered as relatively high-
Topics in the following subcategories will take longer to deal
with, either because of the volume involved, or because of they
represent more fundamental changes in the approach to these services:
E. Accreditation of services generally: 6.8 and 6.8(A).
F. Discourage or ban such services: 6.9.
This would fit with the notion that privacy services to protect an
individual's privacy are legitimate. Are there legitimate reasons
why a corporate entity may not want their details available?
G. Allow such registrations only for non-commercial purposes: 6.11.
Please provide your reactions/comments on the list.