| Comment Close Date | Statement Name | Status | Assignee(s) and | Call for Comments | Call for Comments Close | Vote Announcement | Vote Open | Vote Reminder | Vote Close | Date of Submission | Staff Contact and Email | Statement Number |
|---|---|---|---|---|---|---|---|---|---|---|---|---|
| n/a | Policy Development Process (PDP) on Privacy & Proxy Services Accreditation Issues | Drafting | Alan Greenberg | 17.04.2014 | 23.04.2014 20:00 UTC | 24.04.2014 00:00 UTC | 24.04.2014 00:00 UTC | 30.04.2014 | 01.05.2014 23:59 UTC | *23.04.2014 22:00 UTC | Glen de Saint Gery gnso.secretariat@gnso.icann.org | TBC |
For information about this PC, please click here.
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FINAL VERSION TO BE SUBMITTED IF RATIFIED
The final version to be submitted, if the draft is ratified, will be placed here by upon completion of the vote.
FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
The ALAC strongly supports amending the Privacy Proxy Specification such that:
- It is applicable to all Privacy and Proxy providers.
- The personal details of the beneficial user are verified in accordance with verification requirements in the 2013 RAA. The process should ensure that, at least when the information is collected, that the proposed beneficial user is a real person/organisation and that the contact details are those of the proposed beneficial user.
- Limits on access to the personal information of the beneficial user must be clear and balance the legitimate privacy requirements of the beneficial user as against the legitimate needs of law enforcement agencies and UDRP providers.
The ALAC further advises that in the case where a beneficial user is revealed during the process of a UDRP, and that UDRP proceeding finds in favour of the registrant and not the entity filing the UDRP, the identity and contact information of the beneficial user must NOT be revealed in any public document resulting from the UDRP.
FIRST DRAFT SUBMITTED
The ALAC strongly supports amending the Privacy Proxy Specification such that:
- It is applicable to all Privacy and Proxy providers.
- The personal details of the beneficial user are verified in accordance with verification requirements in the 2013 RAA. The process should ensure that, at least when the information is collected, that the proposed beneficial user is a real person/organisation and that the contact details are those of the proposed beneficial user.
- Limits on access to the personal information of the beneficial user must be clear and balance the legitimate privacy requirements of the beneficial user as against the legitimate needs of law enforcement agencies and UDRP providers.
One further thought. The current UDRP process requires that the beneficial user be reported in the results of the UDRP, regardless of outcome. This allows a beneficial user to be revealed publicly even if the win the dispute and if the UDRP was filed with the explicit intent of revealing the beneficial user. I would suggest that in the interest of protecting registrants who opt for privacy, we recommend that the PDP WG consider the possibility of the beneficial user not be revealed in the case of a failed UDRP. It is unclear (to me) if this is strictly within the scope of the PDP, but if not, the WG could make a recommendation that this be done when the UDRP is revised (scheduled in the near future).
