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[council] Public Comment: Inter-Registrar Transfer Policy Part B Working Group Presents Proposed Final Report
- To: Council GNSO <council@xxxxxxxxxxxxxx>
- Subject: [council] Public Comment: Inter-Registrar Transfer Policy Part B Working Group Presents Proposed Final Report
- From: Glen de Saint Géry <Glen@xxxxxxxxx>
- Date: Mon, 21 Feb 2011 11:45:36 -0800
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- Thread-topic: Public Comment: Inter-Registrar Transfer Policy Part B Working Group Presents Proposed Final Report
http://www.icann.org/en/announcements/announcement-21feb11-en.htm
Public Comment: Inter-Registrar Transfer Policy Part B Working Group Presents
Proposed Final Report
Nine (9) Recommendations for Community Consideration
21 February 2011
The GNSO Inter-Registrar Transfer Policy (IRTP) Part B Policy Development
Process Working Group was tasked to address five issues focusing on issues
related to domain hijacking, the urgent return of an inappropriately
transferred name and "lock status". Following review of the public comments
received on the Initial Report and further deliberations, the Working Group now
presents its proposed Final Report which contains nine (9) recommendations to
address the five charter questions it was tasked with. Before finalizing its
report and submitting it to the GNSO Council for its consideration, the Working
Group is asking for your input on the proposed Final Report, especially the
proposed recommendations. Comments can be submitted until 31 March 2011.
For those interested, the IRTP Part B Working Group will present its report and
proposed recommendations at the ICANN meeting in San Francisco (see
http://svsf40.icann.org/sched-overview for further details).
The Recommendations
Recommendation #1: The WG is considering recommending requiring registrars to
provide an Emergency Action Channel (as described in SAC007 [PDF, 400 KB]). The
WG recognizes that there are further details that would need to be worked out
in relation to this proposal such as:
Within what timeframe should a response be received after an issue has been
raised through the Emergency Action Channel (for example, 24 hours - 3 days has
been the range discussed by the WG)?
What qualifies as 'a response'? Is an auto-response sufficient?
Should there be any consequences when a response is not received within the
required timeframe?
Is there a limited time following a transfer during which the Emergency Action
Channel can be used?
Which issues may be raised through the Emergency Action Channel?
How/who should document the exchanges of information on the Emergency Action
Channel?
Who is entitled to make use of the Emergency Action Channel?
The WG is requesting input from the ICANN Community on these questions and the
recommendation itself, so this can be factored into the WG deliberations going
forward.
Recommendation #2: The WG notes that in addition to reactive measures such as
outlined in recommendation #1, proactive measures to prevent hijacking are of
the utmost importance. As such, the WG strongly recommends the promotion by
ALAC and other ICANN structures of the measures outlined in the recent report
of the Security and Stability Advisory Committee on A Registrant's Guide to
Protecting Domain Name Registration Accounts (SAC 044). In particular, the IRTP
WG recommends that registrants consider the measures to protect domain
registrar accounts against compromise and misuse described in SAC044, Section
5. These include practical measures that registrants can implement "in house",
such as ways to protect account credentials and how to incorporate domain name
registrations into employee or resource management programs typically found in
medium and large businesses. It suggests ways that registrants can use renewal
and change notifications from registrars as part of an early warning or
alerting system for possible account compromise.
Recommendation #3: The WG recommends requesting an Issues Report on the
requirement of 'thick' WHOIS for all incumbent gTLDs. The benefit would be that
in a thick registry one could develop a secure method for a gaining registrar
to gain access to the registrant contact information. Currently there is no
standard means for the secure exchange of registrant details in a thin
registry. In this scenario, disputes between the registrant and admin contact
could be reduced, as the registrant would become the ultimate approver of a
transfer. Such an Issue Report and possible subsequent Policy Development
Process should not only consider a possible requirement of 'thick' WHOIS for
all incumbent gTLDs in the context of IRTP, but should also consider any other
positive and/or negative effects that are likely to occur outside of IRTP that
would need to be taken into account when deciding whether a requirement of
'thick' WHOIS for all incumbent gTLDs would be desirable or not.
Recommendation #4: The WG notes that the primary function of IRTP is to permit
Registered Name Holders to move registrations to the Registrar of their choice,
with all contact information intact. The WG also notes that IRTP is widely used
in the domain name community to affect a "change of control," moving the domain
name to a new Registered Name Holder. The discussions within the WG and with
ICANN Staff have determined that there is no defined "change of control"
function. Therefore, the IRTP-B WG recommends requesting an Issue Report to
examine this issue, including an investigation of how this function is
currently achieved, if there are any applicable models in the country-code name
space, and any associated security concerns.
Recommendation #5: The WG recommends modifying section 3 of the IRTP to require
that the Registrar of Record/Losing Registrar be required to notify the
Registered Name Holder/Registrant of the transfer out. The Registrar of Record
has access to the contact information for the Registrant and could modify their
systems to automatically send out the Standardized Form for Losing Registrars
("Confirmation FOA") to the Registrant.
Recommendation #6: The WG does recognize that the current language of denial
reason #6 is not clear and leaves room for interpretation especially in
relation to the term 'voluntarily' and recommends therefore that this language
is expanded and clarified to tailor it more to explicitly address
registrar-specific (i.e. non-EPP) locks in order to make it clear that the
registrant must give some sort of informed opt-in express consent to having
such a lock applied, and the registrant must be able to have the lock removed
upon reasonable notice and authentication. The WG recommends to modify denial
reason #6 as follows: Express objection to the transfer by the Transfer
Contact. Objection could take the form of specific request (either by paper or
electronic means) by the Transfer Contact to deny a particular transfer
request, or a general objection to all transfer requests received by the
Registrar, either temporarily or indefinitely. In all cases, the objection must
be provided with the express and informed consent of the Transfer Contact on an
opt-in basis and upon request by the Transfer Contact, the Registrar must
remove the lock or provide a reasonably accessible method for the Transfer
Contact to remove the lock within five (5) calendar days.
Recommendation #7: The WG recommends that if a review of the UDRP is conducted
in the near future, the issue of requiring the locking of a domain name subject
to UDRP proceedings is taken into consideration.
Recommendation #8: The WG recommends standardizing and clarifying WHOIS status
messages regarding Registrar Lock status. The goal of these changes is to
clarify why the Lock has been applied and how it can be changed. Based on
discussions with technical experts, the WG does not expect that such a
standardization and clarification of WHOIS status messages would require
significant investment or changes at the registry/registrar level. The WG
recommends that ICANN staff is asked to develop an implementation plan for
community consideration which ensures that a technically feasible approach is
developed to implement this recommendation.
Recommendation #9: The WG recommends deleting denial reason #7 as a valid
reason for denial under section 3 of the IRTP as it is technically not possible
to initiate a transfer for a domain name that is locked, and hence cannot be
denied, making this denial reason obsolete. Instead denial reason #7 should be
replaced by adding a new provision in a different section of the IRTP on when
and how domains may be locked or unlocked. The WG recommends that ICANN staff
is asked to develop an implementation plan for community consideration
including proposed changes to the IRTP to reflect this recommendation.
Background
The IRTP Part B Policy Development Process (PDP) is the second in a series of
five PDPs that address areas for improvements in the existing Inter-Registrar
Transfer Policy. The Inter-Registrar Transfer Policy (IRTP) aims to provide a
straightforward procedure for domain name holders to transfer their names from
one ICANN-accredited registrar to another should they wish to do so. The policy
also provides standardized requirements for registrar handling of such transfer
requests from domain name holders. The policy is an existing community
consensus policy that was implemented in late 2004 and is now being reviewed by
the GNSO.
Deadline and how to submit comments
Comments are welcome via e-mail to irtp-b-proposed-final-report@xxxxxxxxx until
31 March 2011.
Access to the public comment forum from which comments can be posted can be
found at:
http://www.icann.org/en/public-comment/public-comment-201103-en.htm#irtp-b-proposed-final-report
An archive of all comments received will be publicly posted at:
http://forum.icann.org/lists/irtp-b-proposed-final-report/
Further information
IRTP Part B PDP Proposed Final Report [PDF, 734 KB]
IRTP Part B PDP Proposed Final Report - Executive Summary only [PDF, 320 KB]
IRTP Part B PDP Initial Report [PDF, 765 KB]
Inter-Registrar Transfer Policy (IRTP)
Staff responsible: Marika Konings
Glen de Saint Géry
GNSO Secretariat
gnso.secretariat@xxxxxxxxxxxxxx
http://gnso.icann.org
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