[gnso-thickwhois-dt] Comments on the Thick Whois PDP Draft Charter

["Drazek, Keith" <kdrazek@xxxxxxxxxxxx>]

Hi everyone,

Thanks to Marika for the great work kicking off the draft charter.

A few suggested edits:

1. I recommend amending the introductory sentence in Section 2, Mission & Scope 
from, "The PDP Working Group is tasked to provide the GNSO Council with a 
recommendation(s) on whether there should be a requirement for 'thick' Whois 
for all gTLD Registries" to "The PDP Working Group is tasked to provide the 
GNSO Council with a recommendation(s) on the consistent use of 'thick' Whois by 
all gTLD Registries."  The original wording appears to be focused on com and 
net only, where "the consistent use of thick Whois for all gTLD registries" 
allows for any future developments or modifications affecting all implementers 
of thick Whois and ensures that users of thick Whois can rely on a standard or 
consistent experience. In other words, just requiring the use of 'thick Whois' 
is insufficient; the WG should be making a recommendation concerning the 
consistent use of thick Whois among all registry operators.  This also ensures 
the PDP WG's eventual policy recommendation addresses the consistent use of 
thick Whois for all registries as a whole, and does not inappropriately single 
out one registry operator. Note that "consistent use" doesn't preclude 
variations in the model as required by sponsored TLDs, etc.

2. The list of bulleted items looks very comprehensive, but I recommend the 
Drafting Team spend some time adding specificity to the list. The more specific 
we are in the charter, the better off we'll be in determining whether the WG is 
successful in adequately addressing the issues, and knowing when each item is 
completed. I suggest that at least a sentence be added to each item in the list 
to provide a fuller explanation to make the charter clearer.  Ideally, it would 
be helpful for each item to also have a list of questions to be answered; this 
would provide a more precise guide for the work to be done and would make it 
easier to measure completion.  The list itself is good, but each bullet should 
be expanded upon.

Here's an example:

For the bullet: "Impact on privacy and data protection, including consideration 
of possible cross border transfers of registrant data" it will be important 
that the WG answer questions like these:

*         Would registries and/or registrars be required to obtain consents 
from new and existing registrants before processing transfers?

*         Would registries and/or registrars be required to abide by different 
privacy and data protection laws in different jurisdictions?

*         How substantial are the compliance issues for registries and/or 
registrars with regard to varying privacy and data protection laws?
Note that these questions are applicable to both existing registries and new 
registries because all registries will have to deal with transfers of domains 
and transfers of data"


I look forward to discussing further on Thursday and welcome any comments.

Thanks and regards,
Keith




Keith Drazek
Director of Policy
kdrazek@xxxxxxxxxxxx

m: +1-571-377-9182
21345 Ridgetop Circle Dulles, VA 20166

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