<<<
Chronological Index
>>> <<<
Thread Index
>>>
WHOIS Review Team Submission
- To: "whoisrt-discussion-paper@xxxxxxxxx" <whoisrt-discussion-paper@xxxxxxxxx>
- Subject: WHOIS Review Team Submission
- From: "Michele Neylon :: Blacknight" <michele@xxxxxxxxxxxxx>
- Date: Sun, 26 Jun 2011 13:53:47 +0000
Following up on the public meeting in Singapore here are a few notes / thoughts
on WHOIS for the Review Team's consideration.
WHOIS is a very emotive topic and any discussion around it tends to get "bogged
down" very quickly. I would like to thank the Review Team for trying to bring a
clear focus to the topic with their discussion paper, as I realise that it is
not an easy task.
As a registrar I find the current RAA's stipulations regarding whois to be
problematic, as they demand that we make available both public whois (without
any limitations), offer bulk whois access to anyone who asks for it AND demand
that we protect our registrants from unsolicited marketing etc., I honestly
don't see how those requirements can co-exist and I also have grave concerns
about them with respect to EU privacy law.
There is a process for registrars to get an exception, however I am not aware
of any registrar availing of it to date:
http://www.icann.org/en/processes/icann-procedure-17jan08.htm
3. What insight can country code TLDs (ccTLDs) offer on their response to
domestic laws and how they have or have not modified their ccTLD WHOIS policies?
A lot of European ccTLDs offer a whois service that is limited in the amount of
non-technical information that is divulged to the public. Law enforcement can
access the full details via established procedures.
In many cases there is a clear distinction made between a personal domain
registration and that made by one of a business.
Taking the example of the .ie ccTLD:
blacknight.ie is registered to a company and this is clearly reflected in the
WHOIS output:
domain: blacknight.ie
descr: Blacknight Internet Solutions Limited
descr: Body Corporate (Ltd,PLC,Company)
descr: Corporate Name
admin-c: AAE553-IEDR
tech-c: AAM456-IEDR
renewal: 21-August-2011
status: Active
nserver: ns.blacknightsolutions.com
nserver: ns2.blacknightsolutions.com
source: IEDR
person: Blacknight.com Hostmaster
nic-hdl: AAE553-IEDR
source: IEDR
person: Blacknight.ie Hostmaster
nic-hdl: AAM456-IEDR
source: IEDR
While a "personal" name would be shown as per the example below:
domain: paulmkelly.ie
descr: Paul Kelly
descr: Natural Person
descr: Personal Name
admin-c: AIQ195-IEDR
tech-c: AAM456-IEDR
renewal: 09-January-2013
status: Active
nserver: NS1.BLACKNIGHT.COM
nserver: NS2.BLACKNIGHT.COM
source: IEDR
person: Paul Kelly
nic-hdl: AIQ195-IEDR
source: IEDR
person: Blacknight.ie Hostmaster
nic-hdl: AAM456-IEDR
source: IEDR
In both cases it is clear what kind of person or entity registered the domain
name. In both cases no personal data, such as email addresses, phone numbers
etc., are available in WHOIS.
Other ccTLDs are less verbose, such as .co.uk
Domain name:
mneylon.co.uk
Registrant:
Michele Neylon
Registrant type:
Non-UK Individual
Registrant's address:
The registrant is a non-trading individual who has opted to have their
address omitted from the WHOIS service.
Registrar:
Blacknight Internet Solutions Ltd t/a Blacknight Solutions [Tag =
BLACKNIGHT-IE]
URL: http://www.blacknight.com
Relevant dates:
Registered on: 28-Jun-2006
Renewal date: 28-Jun-2012
Last updated: 07-Feb-2011
Registration status:
Registered until renewal date.
Name servers:
ns1.blacknight.com
ns2.blacknight.com
The whois output clearly shows that I have "opted out", as I am not "trading"
A company, however, would not have that option under the Nominet policy, so the
whois ends up like this:
Domain name:
blacknightsolutions.co.uk
Registrant:
Blacknight Internet Solutions Ltd
Registrant type:
Non-UK Corporation
Registrant's address:
Unit 12a,Barrowside Business Park,
Sleaty Road
Carlow
Co. Carlow
00000
Ireland
Registrar:
Blacknight Internet Solutions Ltd t/a Blacknight Solutions [Tag =
BLACKNIGHT-IE]
URL: http://www.blacknight.com
Relevant dates:
Registered on: 01-Sep-2002
Renewal date: 01-Sep-2012
Last updated: 07-Feb-2011
Registration status:
Registered until renewal date.
Name servers:
ns.blacknightsolutions.com
ns2.blacknightsolutions.com
While the business domain does have more data published in WHOIS there is no
email address or phone number.
Under .eu command line whois is limited to the bare technical details:
Domain: blacknight
Registrant:
NOT DISCLOSED!
Visit www.eurid.eu for webbased whois.
Registrar Technical Contacts:
Name: Blacknight Hostmaster
Organisation: Blacknight Internet Solutions Ltd.
Language: en
Phone: +353.599183072
Fax: +353.599164239
Email: accounts@xxxxxxxxxxxxx
Registrar:
Name: Blacknight Internet Solutions Ltd
Website: www.blacknight.com
Name servers:
ns.blacknightsolutions.com
ns2.blacknightsolutions.com
It's only a matter of coincidence that we are the technical contact for our own
domain (an obvious choice!)
With a personal registration the output is pretty much identical:
Domain: micheleneylon
Registrant:
NOT DISCLOSED!
Visit www.eurid.eu for webbased whois.
Registrar Technical Contacts:
Name: Blacknight Hostmaster
Organisation: Blacknight Internet Solutions Ltd.
Language: en
Phone: +353.599183072
Fax: +353.599164239
Email: accounts@xxxxxxxxxxxxx
Registrar:
Name: Blacknight Internet Solutions Ltd
Website: www.blacknight.com
Name servers:
ns.blacknightsolutions.com
ns2.blacknightsolutions.com
If you want to access more verbose details then you need to go to the
registry's whois site where you will be able to access more information about
the business registered domain, while the personal one's output will be limited
to an image of the email address ie. it is not accessible to automated bots
scraping the details.
The only gTLD to date that has followed a similar model is .tel. With .tel
registrants can opt out along similar lines to co.uk and the whois output will
be minimal:
Domain ID: D649645-TEL
Sponsoring Registrar: BLACKNIGHT INTERNET SOLUTIONS LTD
Sponsoring Registrar IANA ID: 1448
Registrar URL (registration services): www.blacknight.com
Domain Status: clientTransferProhibited
Registrant Name: Michele Neylon
Name Server: A0.CTH.DNS.NIC.TEL
Name Server: D0.CTH.DNS.NIC.TEL
Name Server: N0.CTH.DNS.NIC.TEL
Name Server: S0.CTH.DNS.NIC.TEL
Name Server: T0.CTH.DNS.NIC.TEL
Created by Registrar: TUCOWS INC.
Last Updated by Registrar: BLACKNIGHT INTERNET SOLUTIONS LTD
Last Transferred Date: Tue Mar 09 16:45:41 GMT 2010
Domain Registration Date: Mon Mar 23 23:59:59 GMT 2009
Domain Expiration Date: Fri Mar 22 23:59:59 GMT 2013
Domain Last Updated Date: Wed Mar 10 11:09:32 GMT 2010
While a business registration would look something like this:
Domain Name: BLACKNIGHT.TEL
Domain ID: D591748-TEL
Sponsoring Registrar: BLACKNIGHT INTERNET SOLUTIONS LTD
Sponsoring Registrar IANA ID: 1448
Registrar URL (registration services): www.blacknight.com
Domain Status: ok
Registrant ID: TUDHRH3SZ9DINEQF
Registrant Name: Michele Neylon
Registrant Organization: Blacknight Internet Solutions Ltd
Registrant Address1: Barrowside Business Park
Registrant Address2: Unit 12a
Registrant Address3: Sleaty Road
Registrant City: Carlow
Registrant State/Province: Co Carlow
Registrant Postal Code: 000000
Registrant Country: Ireland
Registrant Country Code: IE
Registrant Phone Number: +353.599183072
Registrant Email: management@xxxxxxxxxxxxx
Administrative Contact ID: TURPH7M0XB4O2DZO
Administrative Contact Name: Michele Neylon
Administrative Contact Organization: Blacknight Internet Solutions Ltd
Administrative Contact Address1: Barrowside Business Park
Administrative Contact Address2: Unit 12a
Administrative Contact Address3: Sleaty Road
Administrative Contact City: Carlow
Administrative Contact State/Province: Co Carlow
Administrative Contact Postal Code: 000000
Administrative Contact Country: Ireland
Administrative Contact Country Code: IE
Administrative Contact Phone Number: +353.599183072
Administrative Contact Email: management@xxxxxxxxxxxxx
Billing Contact ID: TURO0PYDHUERE11M
Billing Contact Name: Michele Neylon
Billing Contact Organization: Blacknight Internet Solutions Ltd
Billing Contact Address1: Barrowside Business Park
Billing Contact Address2: Unit 12a
Billing Contact Address3: Sleaty Road
Billing Contact City: Carlow
Billing Contact State/Province: Co Carlow
Billing Contact Postal Code: 000000
Billing Contact Country: Ireland
Billing Contact Country Code: IE
Billing Contact Phone Number: +353.599183072
Billing Contact Email: management@xxxxxxxxxxxxx
Technical Contact ID: TUJJC18TGSETV3QQ
Technical Contact Name: Michele Neylon
Technical Contact Organization: Blacknight Internet Solutions Ltd
Technical Contact Address1: Barrowside Business Park
Technical Contact Address2: Unit 12a
Technical Contact Address3: Sleaty Road
Technical Contact City: Carlow
Technical Contact State/Province: Co Carlow
Technical Contact Postal Code: 000000
Technical Contact Country: Ireland
Technical Contact Country Code: IE
Technical Contact Phone Number: +353.599183072
Technical Contact Email: management@xxxxxxxxxxxxx
Name Server: A0.CTH.DNS.NIC.TEL
Name Server: D0.CTH.DNS.NIC.TEL
Name Server: N0.CTH.DNS.NIC.TEL
Name Server: S0.CTH.DNS.NIC.TEL
Name Server: T0.CTH.DNS.NIC.TEL
Created by Registrar: INJECTCSR
Last Updated by Registrar: TUCOWS INC.
Last Transferred Date: Wed Mar 02 23:46:19 GMT 2011
Domain Registration Date: Mon Mar 23 23:59:59 GMT 2009
Domain Expiration Date: Fri Mar 22 23:59:59 GMT 2013
Domain Last Updated Date: Wed Mar 02 23:46:19 GMT 2011
Registrar Fields
----------------
TrademarkRegistrationDate: 2006/10/26
4. How can ICANN balance the privacy concerns of some registrants with its
commitment to having accurate and complete WHOIS data publicly accessible
without restriction?
I don't think it can. There are many valid reasons why a registrant may wish to
keep some of their data private. I'm also not convinced that making complete
WHOIS data available without restriction is such a good idea
5. How should ICANN address concerns about the use of privacy/proxy services
and their impact on the accuracy and availability of the WHOIS data?
If ICANN were able to address the privacy concerns of individuals then a lot of
the issues surrounding privacy / proxy services would probably disappear.
6. How effective are ICANN’s current WHOIS related compliance activities?
They are open to abuse. In many cases WHOIS complaints are more to do with
disputes between 3rd parties than any lack of compliance.
7. Are there any aspects of ICANN’s WHOIS commitments that are not currently
enforceable?
8. What should ICANN do to ensure its WHOIS commitments are effectively
enforced?
9. Does ICANN need any additional power and/or resources to effectively enforce
its existing WHOIS commitments?
10. How can ICANN improve the accuracy of WHOIS data?
Give private registrants the ability to "opt out".
11. What lessons can be learned from approaches taken by ccTLDs to the accuracy
of WHOIS data?
12. Are there barriers, cost or otherwise, to compliance with WHOIS policy?
Validation of registrant data is a costly process. Registrars rely on the data
being given to them as being given in "good faith".
While it might be possible to validate some of the input, such as an email
address, it is financially prohibitive to attempt to validate all aspects of
registrant data.
13. What are the consequences or impacts of non-compliance with WHOIS policy?
Mr Michele Neylon
Blacknight Solutions
Hosting & Colocation, Brand Protection
ICANN Accredited Registrar
http://www.blacknight.com/
http://blog.blacknight.com/
http://blacknight.mobi/
http://mneylon.tel
Intl. +353 (0) 59 9183072
US: 213-233-1612
UK: 0844 484 9361
Fax. +353 (0) 1 4811 763
-------------------------------
Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
Road,Graiguecullen,Carlow,Ireland Company No.: 370845
<<<
Chronological Index
>>> <<<
Thread Index
>>>
|