Explore the Draft Next Generation gTLD Directory Services Model

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FINAL VERSION TO BE SUBMITTED IF RATIFIED

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FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC

The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.ALAC has previously expressed its concerns with compliance with the RAA, in particular, both the wording of the RAA which made accuracy requirements difficult to enforce and the difficulty with the ICANN Compliance department in acting to ensure such accuracy. These concerns were echoed in the Final Whois Policy Review Team Report, which the ALAC supported.

The ALAC, therefore, supported the important changes to the RAA and related documents as accepted by the Board in June of this year that hold out promise for significant changes including:

• Stronger obligations on registrars for verification
• Stronger accuracy requirements
• Stronger language for enforcement
• At least a skeleton framework for privacy/proxy services

It is against that background that the ALAC is commenting on the proposals by the Expert Working Group for the Aggregated Registration Data Service (ARDS).

Our first issue is that the significant reforms to Whois data - its access, accuracy and enforcability - have been addressed in reforms to the RAA and related documents. Work on development of the ARDS should not be used as any reason to avoid fully implementing those significant reforms.

That said, the ARDS proposal contains many important changes to the issues surrounding registration data which the ALAC supports.  

Specifically, we strongly support the following elements of the ARDS proposal:

• The allowance of tiered access to registration data.  The public will still have access to some Whois data, but only those with recognised reasons to access specific data will be able to do so - thus addressing some legitimate privacy concerns with all Whois data being publicly available;
• The provision of a centralised responsibility for data accuracy.

There are still significant issues that will need to be worked through, such as determining who has access to what data, for what reason, and how will the compliance function relating to such service be enforced.

In addition to the above, although this proposal is not intended to look at implementation details, the model must be designed with implementation in mind, including ensuring privacy, reliability, resiliency and addressing jurisdictional issues.

We support continuing discussions on the development of the ARDS proposal, and expect to continue to be involved in those discussion.

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FIRST DRAFT SUBMITTED

ALAC has previously expressed its concerns with compliance with the RAA, in particular, both the wording of the RAA which made accuracy requirements difficult to enforce and the difficulty with the ICANN Compliance in ensuring such accuracy. The concerns were echoed in the Final Whois Policy Review Team Report, which ALAC supported.

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