Public Comment

Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.

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Name: Sarah Wyld
Date: 14 Oct 2022
Affiliation: Tucows
Please provide your feedback:
Section 1 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 2 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 3 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 4 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 5 does not accurately reflect the intent of the Registration Data Consensus Policy. (Please provide an explanation including Recommendations from the EPDP-TempSpec Phase 1 or Phase 2 Final Report where there are inconsistencies and the suggested change to make this section consistent.)

If B, C, or D, please elaborate.

We strongly urge ICANN to collaboratively finalize and then sign the DPA which has been in discussion for several years. The language in the Draft Registration Data Consensus Policy is ambiguous where the Recommendations of the EPDP Phase 1 are not. For example, the Draft Registration Data Consensus Policy says “relevant third party providers” but does not indicate who can designate third party providers as “relevant”. The EPDP Phase 1 Recommendations clearly intended Contracted Parties to be able to designate third party providers, both to themselves and to ICANN, as “relevant”. Further, ICANN MUST enter into data protection agreements with Data Escrow Providers but the language in the Draft Registration Data Consensus Policy allows ICANN to avoid this requirement because of its linguistic ambiguity. Tucows’ Recommended Language for Section 5: If Registry Operator or Registrar determines that such agreements are required by applicable law, Registry Operator and Registrar MUST make the request without undue delay pursuant to this policy for data protection agreements between the Contracted Party and ICANN and for data protection agreements between ICANN and a relevant third party provider. ICANN MUST without undue delay enter into data protection agreement or agreements upon such request.

Please provide your feedback:
Section 6 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 7 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 8 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 9 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 10 accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

§10.6 uses the ambiguous term “business days” and should rather specify that it is the registrar's business days that are relevant. Tucows' Recommended Language for Section 10: For Urgent Requests for Lawful Disclosure, Registrar and Registry Operator MUST acknowledge and respond without undue delay, but no more than two (2) business days (as determined by the recipient) from receipt.

Please provide your feedback:
Section 11 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Section 12 accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Addendum I accurately reflects the policy recommendations; however, the following clarification(s) are suggested. (Please provide the suggested language change.)

If B, C, or D, please elaborate.

While this section accurately reflects the Policy Recommendation language, we think it could be more clear. Tucows’ Recommended Language for Addendum I: Note: this Addendum I applies to contracted parties providing WHOIS (available via port 43) or web-based Whois directory services only if required by the Registrar Accreditation Agreement or ICANN Consensus Policy.

Please provide your feedback:
Addendum II accurately reflects the policy recommendations with no issues.
Please provide your feedback:
Additional concern or issue identified in Section 15. (Please describe further.)

If B, C, or D, please elaborate.

The final paragraph of the Draft Registration Data Policy should be completed before the Draft becomes Policy.

Please provide your feedback:
Background Section accurately reflects the policy recommendations with no issues.
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the AWIP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the ERRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Protection of IGO and INGO Identifiers in all gTLDs Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the CL&D Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the RNAP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Revised ICANN Procedure for Handling Whois Conflicts with Privacy Law correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Thick Whois Transition Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Transfer FOA Confirmation correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Transfer FOA Initial Authorization correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the TDRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Transfer Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the UDRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the UDRP Rules correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the URS Procedure correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the URS Rules correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the URS Requirements correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the WDRP correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, are the proposed redlined changes identified in the Whois Marketing Restriction Policy correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, is the proposed Advisory Clarifications to the Registry and Registrar Requirements for Whois Data Directory Services correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, is the proposed the RDAP Technical Implementation Guide correct?
Yes
Based on the requirements outlined in the Registration Data Consensus Policy, is the proposed RDAP Response Profile correct?
Yes
Summary of Submission

Tucows thanks the IPT and IRT for their many hours of work and diligent efforts in translating the Working Group Recommendations into Policy. The Registration Data Policy for the most part accurately reflects the Recommendations; Tucows has suggested modifications to Sections 5, and 10, Addendum I, and the Implementation Notes.