WHOIS1 Rec #10: Privacy/Proxy Services

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

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

WHOIS1 Implementation Briefings on Recommendations 5, 8, 10, 11: PPT, PDF
Answers to RDS-WHOIS2 Questions on Implementation Briefings
WHOIS Review Team (WHOIS1) Final Report (2012) and Action Plan
WHOIS Review Team (WHOIS1) Implementation Reports, including
- Executive Summary of Implementation Report
- Detailed implementation Report
Documents cited in briefing on Recommendation 10 include
(20 March)
Additional links specific to Recommendation 10 may be added here

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

Leader/Rapporteur: Volker Greimann Members: Cathrin Bauer-Bulst, Stephanie Perrin, Susan Kawaguchi, Volker Greimann, Dmitry Belyavsky Mailing-list archives: http://mm.icann.org/pipermail/rds-whois2-privacy-proxy/ Conference calls: see here Review Team Templates: see here

Leader/Rapporteur: Volker Greimann Members: Cathrin Bauer-Bulst, Stephanie Perrin, Susan Kawaguchi, Volker Greimann, Dmitry Belyavsky Mailing-list archives: http://mm.icann.org/pipermail/rds-whois2-privacy-proxy/ Conference calls: see here Review Team Templates: see here

Subgroup Documents

DOCX

Date	Document (Versions in Red are latest)	File

Date	Document (Versions in Red are latest)	File
Subgroup Report
Aug 10, 2018	v9
Aug 2, 2018	v8
Jul 30, 2018	v7 (incl. FtoF #3 Agreements)
Jun 22, 2018	v6
Jun 13, 2018	v5
Jun 6, 2018	v4
May 23, 2018	v3
Apr 10, 2018	v2
Apr 4, 2018	v1	DOCX
Face-to-Face Mtg #2 Slides - Findings
Apr 13, 2018	v2
Apr 9, 2018	v1
	Case Study of P&P Service Abuse (submitted by Lili)
Jun 3, 2018	v1
Planning Questions
Mar 1, 2018	v1
First Pass Document
Feb 8, 2018	v4
Jan 17, 2018	v3
Dec 11, 2017	v2	DOCX
Dec 6, 2017	v1	DOCX

ICANN Org Briefings/Answers

, includes:
- 20 March written answers to PP IRT related questions
- Metrics for P/P Spec in the 2013 RAA
(27 March)

Open Actions/Requests

Item #	Source of Request	Date of Request	Action Item Request	Action Owner	Anticipated Completion Date*	Progress Notes

Item #	Source of Request	Date of Request	Action Item Request	Action 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 Request	Date of Request	Action Item Request	Action Owner	Anticipated Completion Date*	Progress Notes	Completed Response	Completion Date

Item #	Source of Request	Date of Request	Action Item Request	Action Owner	Anticipated Completion Date*	Completed Response	Completion Date
19	#37	Aug 6, 2018	Apply editorial change "The ICANN Board should recommend to the next review team" to rec 10.2 (also 12.1)	ICANN org			Aug 10, 2018
18	FtoF #3	Jul 27, 2018	Volker to update subgroup report to reflect decisions reached and proposed recommendation.	Volker			Aug 3, 2018
17	#34	Jul 16, 2018	Volker to address any concerns raised in a final draft to be sent to the full RT by the end of this week.	Volker			Aug 3, 2018
16	#34	Jul 16, 2018	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	Jun 14, 2018	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	Jun 21, 2018
14	#3	Jun 14, 2018	Volker to reword Issue #2 (impact of GDPR) to clarify comment but make no recommendation	Volker		Email	Jun 21, 2018
13	#3	Jun 14, 2018	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 this	Volker		Email	Jun 21, 2018
12	#3	Jun 14, 2018	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	Jun 21, 2018
11	#3	Jun 14, 2018	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	Jun 21, 2018
10	#28	Jun 11, 2018	ICANN org to prepare and send out doodle for a subgroup meeting (incl. Stephanie) this week, based on Volker's availability.	ICANN org		Email	Jun 11, 2018
9	#27	May 14, 2018	Susan to liaise with Volker and progress on the subgroup draft report.	Susan		Email	May 24, 2018
7	#26	Apr 17, 2018	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	May 2, 2018
8	#26	Apr 18, 2018	Dmitry to be added to Rec #10: Privacy/Proxy Services	ICANN org			Apr 18, 2018
6	#25	Apr 6, 2018	Susan to touch base with Volker on subgroup report	Susan		Email	Apr 25, 2018
5	#22	Mar 5, 2018	Susan to review list of questions in light of Alan's comments https://mm.icann.org/pipermail/rds-whois2-privacy-proxy/2018-March/000016.html	Susan	/	Email	Mar 12, 2018
3	#1	Feb 26, 2018	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	Mar 20, 2018	Email	Mar 20, 2018
4	#1	Feb 26, 2018	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	Mar 16, 2018	Email	Mar 11, 2018
2	#1	Feb 26, 2018	Provide first draft of questions for IRT compliance team (by 27 Feb).	Susan	Feb 27, 2018	Email	Feb 27, 2018
1	#1	Feb 26, 2018	Draft answers to planning questions and provide to Volker to review and share with subgroup.	ICANN org	Feb 27, 2018	/	Feb 27, 2018

Decisions Reached

Source of request	Date	Decision

Source of request	Date	Decision
FtoF #3	Jul 27, 2018	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