comments by Marilyn Cade, as an individual Business user

["Marilyn Cade" <mscade@xxxxxxx>]

I have read with interest the views posted in comment to the WHOIS TF
report. 

 

I am a representative of the Business Constituency in the WHOIS TF, and I
don't want to repeat the BC positions, which are part of the existing record
and therefore should be part of the existing record. I suggest that none of
the constituencies will have assumed that they needed to post, since their
positions are already incorporated in the preliminary report of the TF and
will thus be taken into account of the work of the TF. 

 

Instead, I want to comment on why I individually believe that an improved
form of notice is needed and to state my support that this will help to
inform individual and business registrants. 

 

I have extensive experience in ensuring that "consumers" are advised of
their rights and responsibilities related to online services through work I
have led in the US in online privacy notices via the Online Privacy
Alliance, and issues related to consumer uses of the Internet.  I appreciate
that the registrars/registries are concerned about multiple notices. In my
experience, separate, distinct notices, that are clear, and are consistent,
are the best way to 1) notify users 2) ensure that there is a level playing
field and that "gaming" doesn't occur through "messaging"

 

I understand that registrars may think that consistent and clear notices
will deter registrations. I do not accept that as a justification to avoid
providing clear and conspicuous notice to registrants. Having information
about their own obligations to provide accurate information is clearly a
service to registrants. For those who chose not to provide this information,
they can use proxy services via third parties. We need to also remember that
many ISPs offer web pages via their service; thus those who prefer not to
provide accurate registration data, do have other options to have a personal
presence on the 'net". . 

 

Thus, I continue to support the goal of consistent, well defined and
identifiable notices. 

 

I respect that the registrars have existing obligations. We should take care
to respect and incorporate those obligations in the consensus policy as it
is implemented. The proposed policy doesn't challenge that obligation; it
supports it. 

 

Marilyn Cade, posting as an a business user/owner