WHOIS1 Rec #10: Privacy/Proxy Services

Apply editorial change "The ICANN Board should recommend to the next review team" to rec 10.2 (also 12.1)

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 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.

ICANN org to prepare and send out doodle for a subgroup meeting (incl. Stephanie) this week, based on Volker's availability.

Susan to liaise with Volker and progress on the subgroup draft report.

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 

#26

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.

Issue #5 to be expanded to discuss P/P abuse risk, potential for change in P/P use due to GDPR, a reference to the WHOIS P/P Abuse Study, and also to the CCT RT study on P/P and DDARP recommendation (when available).

Issue #3 is subject to confirmation after ICANN legal review is completed: The RT is currently not aware of any need to delay the implementation of accreditation program due to GDPR.

The entire P/P Issues/Problems section should be prefaced with a qualifier that the issues are based on the status of PPSAI policy implementation as of July 2018, and are subject to update as implementation continues.

No change to subgroup’s conclusion that the recommendation to initiate policy development is “fully implemented” but the conclusion should clearly state that policy implementation remains underway.

The subgroup will follow the RT's agreement to not relegislate PDPs. Can raise concerns but should not make recommendations to modify PDP WG's recommendations prior to implementation.

All subgroups members are to review PPSAI and RAA specs on Privacy/Proxy.

Subgroup to review implementation of RT1 recommendation: 2013 RAA specs and PPSAI policies. IRT is underway to policy effective date is unlikely to be this year. Limit subgroup's work to what has been completed and not wait for policy to become effective. 

Subgroup to develop questions for IRT Compliance team.

Rapporteur will collate the findings of all members into a single document. All subgroup members to review/contribute to findings.