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A whois issue to: Re: [ga] Revised Registrar Data Escrow Specifications Posted

  • To: Danny Younger <dannyyounger@xxxxxxxxx>
  • Subject: A whois issue to: Re: [ga] Revised Registrar Data Escrow Specifications Posted
  • From: Jeff Williams <jwkckid1@xxxxxxxxxxxxx>
  • Date: Tue, 24 Apr 2007 01:22:24 -0700
  • Cc: "Gomes, Chuck" <cgomes@xxxxxxxxxxxx>, ga@xxxxxxxxxxxxxx, gnso-whois-wg@xxxxxxxxx
  • Organization: INEGroup Spokesman
  • References: <200093.32544.qm@web52211.mail.re2.yahoo.com>
  • Sender: owner-ga@xxxxxxxxxxxxxx

Danny and all,

  I agree with Danny's concern here.  However the REAL problem
is what data fields are by ICANN policy in Whois and registration
data required, which is damaging to registrant security and privacy.
Ergo by eliminating proxy registrations in favor of the registrant not
being
forced to have his or her personal and private information, i.e.
address, phone number, and fax number, would solve most of
the data escrow problems in respect to and contrast to proxy
registrations.  At the same time, registrants security and privacy
would be better served.

  However the "No privacy" bigots, will of course not like
this approach.

Danny Younger wrote:

> Hello Chuck,
>
> This was the portion of the document that really
> bothered me:
>
> ?       "Registrars that allow registrants to register
> domain names through Whois privacy or proxy services
> that effectively prevent escrow of the beneficial
> domain name users' contact information may optionally
> include additional fields in the text file to escrow
> the names, addresses, telephone/fax numbers, and email
> addresses of the beneficial users."
>
> I wrote directly to Mike Zupke, ICANN's registrar
> liaison about this issue (asking why "optional"
> instead of "mandatory").  He replied:
>
> "Under the current RAA, there is no provision
> requiring registrars to escrow underlying customer
> data when a privacy service is the registrant.  (The
> registrant - for whom data must be escrowed
> - is the registrant listed in whois.)  That's
> something that should be addressed in the RAA revision
> process, but until it is, the Registrar
> Constituency has suggested that registrars at least be
> allowed to escrow such data.  Registrars have
> generally expressed that they intend to take
> advantage of the option to escrow underlying customer
> data as many believe their customers would want it
> that way.  In the short term, we will have to
> come up with a way to notify registrants which
> registrars are escrowing underlying customer data and
> which are not so consumers can at least make an
> educated decision."
>
> I don't find Mike's response to be sufficiently
> satisfying.  If anything, the underlying "real
> registrant" data is that which should be escrowed.  If
> we only escrow the proxy data then we will conceivably
> run into real issues in the event of a registrar
> calamity (think RegisterFly and their ProtectFly
> service).
>
> --- "Gomes, Chuck" <cgomes@xxxxxxxxxxxx> wrote:
>
> > Danny,
> >
> > A critical element in these specifications is the
> > definition of the
> > 'Registered Name Holder'.  It is my understanding
> > that, in some cases
> > where proxy services are used, the 'Registered Name
> > Holder' may be the
> > proxy service provider.  My only point is that it is
> > important that
> > everyone has the same understanding of what is meant
> > by 'Registered Name
> > Holder' and that sufficient data is escrowed to
> > allow for ongoing
> > registration support in case of registrar failure.
> > It is also important
> > to recognize that, except in cases where the
> > registrar is providing the
> > proxy services directly, the proxy service provider
> > probably has no
> > contractual obligations to ICANN.
> >
> > Chuck Gomes
> >
> > "This message is intended for the use of the
> > individual or entity to
> > which it is addressed, and may contain information
> > that is privileged,
> > confidential and exempt from disclosure under
> > applicable law. Any
> > unauthorized use, distribution, or disclosure is
> > strictly prohibited. If
> > you have received this message in error, please
> > notify sender
> > immediately and destroy/delete the original
> > transmission."
> >
> >
> > > -----Original Message-----
> > > From: owner-ga@xxxxxxxxxxxxxx
> > > [mailto:owner-ga@xxxxxxxxxxxxxx] On Behalf Of
> > Danny Younger
> > > Sent: Monday, April 23, 2007 11:32 AM
> > > To: ga@xxxxxxxxxxxxxx
> > > Subject: [ga] Revised Registrar Data Escrow
> > Specifications Posted
> > >
> > >
> >
> http://regbits.info/wp-content/uploads/registrar-data-escrow-s
> > > pecifications-crev3.doc
> > >
> > > Comments?
> > >
> > > __________________________________________________
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Regards,

--
Jeffrey A. Williams
Spokesman for INEGroup LLA. - (Over 134k members/stakeholders strong!)
"Obedience of the law is the greatest freedom" -
   Abraham Lincoln

"Credit should go with the performance of duty and not with what is
very often the accident of glory" - Theodore Roosevelt

"If the probability be called P; the injury, L; and the burden, B;
liability depends upon whether B is less than L multiplied by
P: i.e., whether B is less than PL."
United States v. Carroll Towing  (159 F.2d 169 [2d Cir. 1947]
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