Re: [ga] Escrow Concerns

[Karl Auerbach <karl@xxxxxxxxxxxx>]

On Wed, 2 Mar 2005, Danny Younger wrote:

> I'd like switch the discussion away from ICANN politics for a moment to 
> raise an at-large issue that has been on my mind for some time:  the 
> risk My thanks to Joop and to Bill Nichols for the timely reminder to 
> avoid flaming on this list. to registrants posed by the failure of 
> registrars to escrow data.

The status from when I was on the board was this:

	- Some inadequate formats had been defined.
	- Nobody had bothered to put 'em into play.

The real issue is preservation of registry/registrar business records, in 
particular the records needed to reconstruct the registry/registrar.

This can be handled by escrow ... or by other mechanisms that I believe 
will do the same job with less pain to all concerned and with less 
intrusive regulation.

The mechanism I tend to prefer is to leave the job up to each 
registry/registrar and have them deliver to ICANN (and to publish to the 
community) a yearly statement from an independent auditor (one with 
appropriate expertise) to the effect that the registry/registrar engages 
in business asset protection policies that are adequate to the 
reconstruction of the operations after a disaster or financial failure by 
the registry/registrar or a sucessor.

This audit letter would have to specify not only that are the assets 
protected by adequate practices but also that there is a sufficient body 
of documentation and tools, all of which need to be held by a known third 
party, to recover using no other specialized knowledge, tools, or special 
hardware (e.g. weirdball tape drives.)

This mechanism takes ICANN out of the preservation loop, allows 
registries/registrars to tailor the preservation practices to their own 
needs, allows those practices to evolve (and improve) over time, and let's 
the public know who is doing well in this regard and who is not.

		--karl--