Re: [ga] Escrowing Proxy Data instead of True Registrant Data
I'm not disagreeing with you that the it is in the interests of domain name registrants to have registration systems that do not lose registration data in the case of a catastrophe. However, do we want a centrally designed system of uniform design (one size fits all)? Or do we want to allow flexibility. What I have suggested is rather than having mandate a singular escrow system - something they have been rather bad at establishing - we require registries and registrars to provide a yearly statement from an independent, competent business practices auditor that attests to certain things. In particularly the yearly statement would have to certify that the registry or registrar has in place, in writing, active and practiced data protection and retention practices sufficient to allow the registrar/registry or a successor in interest to revive the registration data and the association of that data with customers. This could, if desired be backed by third party beneficary status to customers, a bond or guarantee in case of non-performance, and a right under which ICANN could require a demonstration that the recovery process actually works. That way the registrars and registries could pick whatever system suits them best. A monolithic escrow system means that we continue to wait for ICANN. Moreover, a monolithic system further entrenches the rather arbitrary business model that ICANN arbitrarily imposes upon the DNS industry. ICANN can still publish an escrow model and offer to act as an agent to hold the data. And if some registrars find that useful they can use it and advertise to potential customers that they use the ICANN escrow system. Then customers can vote with their dollars whether they want to use registrars that use ICANN escrow of ones that have other, but certified, methods of business asset preservation. --karl--
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