Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
If B, C, or D, please elaborate.
The RrSG notes that ICANN has been negotiating a DPA with the contracted parties for several years. The RrSG encourages ICANN to complete these negotiations and to sign the respective DPAs with registrars and registries. Additionally, the RrSG notes that the wording in this section is ambiguous. The recommendation does not specify who can request a DPA, so theoretically a third party can require their own DPA. The recommendation should be clarified to ensure that registrars are not required to negotiate and/or sign substantial DPAs relating to their ICANN accreditation. If it is anticipated that there may be additional DPAs with third parties, then the RrSG recommends that the contracted parties create a standard DPA that can be used.
If B, C, or D, please elaborate.
The RrSG notes that recommendation 6.3 applies only at the time of registration, and suggests that to ensure PII is not inadvertently disclosed publicly, that these requirements also apply when technical contact information is updated. The RrSG is also concerned that registrars may not have a direct relationship with the technical contact, and may not be able to properly obtain consent to display PII. The IRT should resolve this ambiguity.
If B, C, or D, please elaborate.
The RrSG notes that while recommendation 7.2 refers to “Registrar Whois Server”, concurrently the RA and RAA are being amended to primarily replace whois obligations with RDAP requirements. While registrars may continue to provide whois service after the transition from whois to RDAP, the recommendations should include a reference to this change to avoid future ambiguity.
The Registrar Stakeholder Group (RrSG) is pleased to comment on the Registration Data Consensus Policy for gTLDs and thanks the IRT team for their efforts. In general, it is the RrSG’s position that the policies accurately reflects the policy recommendations, with some suggested clarifications. The RrSG also notes that the questions in regards to transfers are under review by the PDP Transfer Policy Review PDP.