Implementation Review Team Meeting Thick WHOIS Policy Implementation Review Team Meeting 17 January 2017

Agenda 1 2 3 4 5 6 Project Status Project Schedule Public Comment Revised Policy Language For Transition Revised Policy Language For CL&D Next Steps

Thick Whois Thick Whois Policy Implementation Status Pubic Comment s Consistent Labeling and Display of RDDS (Whois) Output for All gTLDs policy closed on 12 December 2016 with 5 comments Summary and analysis report published on 11 January 2016 Thick RDDS (Whois) Transition Policy for .COM, .NET and .JOBS policy closed on 16 December 2016 with 4 comments Summary and analysis report in draft to be published The IRT letter regarding emerging privacy issue Submitted to GNSO Council by Amr Elsader (Council Liaison) on 16 December 2016 On the Council meeting agenda for 19 January 2017

CL&D Implementation Path – Timeline Policy effective date announced 6 months Policy Implementation Policy effective date 12 months 6 months 18 months Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun 2017 2018 2019

Transition Implementation Path – Timeline Policy effective date announced 6 months Registries update Registry systems New Registrations Registry OT&E opens Optional thick (Registry production systems) 12 months Registrars transition new registrations from thin to thick Required thick (Registry production systems) Policy effective date for new registrations 6 months Registries prepare for transition Existing Registrations Registry OT&E opens Registrars transition data from thin to thick 3 months Registrars prepare for transition 18 months Policy effective date for existing registrations Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May Jun 2017 2018 2019

Public Comments on CL&D Policy Five comments received: IAB, RySG, Verisign, IPC, and BC While none of the commenters expressed any objection to the proposed revised Policy, some commenters proposed some changes to the proposed revised Policy. The suggestion for revision to be discussed with the IRT in this meeting Other comments related to the policy implementation process and RDAP.

Public Comments on CL&D Policy Comment: "not to be deployed before" date of 1 November 2016. As 1 November 2016 has passed, this language is extraneous and can be removed” (Verisign) the “not to be deployed before” date was included in the initial version of the Policy posted for public comment to allow sufficient lead time to adjust the Pre-delegation Testing (PDT) platform to accommodate the CL&D format. As of now, that development has been completed and the “not to be deployed before” date is no longer needed. IRT discussion

Public Comments on CL&D Policy Comment: "Verisign recommends that the revised proposed CL&D Policy include provisions for ICANN staff to provide extensions to the 1 August 2017 date in appropriate circumstances ” the policy effective date included in the draft Policy aims to afford contracted parties a reasonable period of time, following notice of the establishment of a new consensus policy, to comply with the policy. Consistent with the Consensus Policy Implementation Framework ICANN organization aims to provide contracted parties at least six months lead time to implement new policies. In some cases, in consultation with the Implementation Review Team, additional time for implementation may be warranted if there is a phased implementation. The implementation date included in the current draft Policy has been carefully considered and evaluated with the IRT for more than one year. However, it’s recognized that unforeseen circumstances may arise during the implementation period. In the past, such requests for extension have been handled on an individual basis with consultation between the contracted party and ICANN organization. IRT discussion

Public Comments on Transition Policy Four comments received: Verisign, IPC, BC and an individual While all comments are generally in favor of the proposed policy, some comments suggested changes for the proposed policy. The suggested changes will be discussed in this IRT session. Two comments expressed disappointment on the long timeline for the transition. One comment urges the IRT to move forward and not re-litigate privacy and jurisdiction issue

Public Comments on Transition Policy Comment: RDAP Profile Reference: Section 2.10 of the Thick Whois Transition Policy refers to requirements found in the "RDAP Operational Profile for gTLD Registries and Registrars", a document which is neither a policy nor a standard. Verisign recommends that instead of unnecessarily referencing requirements found in the RDAP Operational Profile, the necessary requirements be explicitly stated in the Thick Whois Transition Policy.” The policy states that “RDAP Operational Profile for gTLD Registries and Registrars if implementing RDAP.” Therefore, this only applies to those who wishes to implement RDAP. Optionally, the section could be deleted from this policy IRT Discussion

Public Comments on Transition Policy Comment: section 2.4 be updated to state that Registry Operators must support the contact commands as described in the provision "by 1 August 2017” in order to clarify the requirements associated with EPP implementation (Verisign) This change allows the Registry Operator to provide support for the contact commands before the 1 August 2017 date in addition to requiring it after 1 August 2017 IRT Discussion

Public Comments on Transition Policy Comment: The EPP contact field <contact:postalInfo> has a number of sub-elements, but the only element the IRT discussed requiring is "type". For clarification, Verisign recommends replacing <contact:postalInfo> with <contact:postalInfo type> in Section 2.4.“ The <contact:postalInfo> contains other important sub-elements such as name and address in addition to the <contact:postalInfo type>. IRT has reviewed drafts containing requirement for <contact:postalInfo>, but not <contact:postalInfo type>. IRT Discussion

Public Comments on Transition Policy Comment: Section 2.8 requires registries to implement the "CL&D" by 1 August 2017. - appear to make Section 2.9 redundant, as Section 2.9 requires registries to implement CL&D for "other than Existing Doman Names" starting 1 May 2018. Similarly Section 2.10 appears to create an "optional" period between 1 August 2017 and 1 February 2019 for certain RDDS Output fields for "Existing Domain Names", but does not address full CL&D implementation following 1 February 2019. (Verisign) 1 August 2017: Registries may implement CL&D for both new and existing registration 1 May 2018: Registries must implement CL&D for new registration  1 Feb 2019: Registries must implement CL&D for existing registration IRT Discussion

Public Comments on Transition Policy Comment: “include specific provisions that define the requirements and procedures for Registry Operators and Registrars to seek a waiver of the requirements … in the event of a conflict with local laws, and that such provisions include one or more "Alternative Triggers" similar to those contained in the Data Retention Specification of the 2013 RAA.” (Verisign) “resist attempts from stakeholders who wish to re-litigate privacy and jurisdictional issues as part of the Thick Whois Implementation. .. Must move forward with implementation ..” (BC) The policy recommendation from PDP WG does not include waiver provisions On going discussion at the GNSO Council regarding the “Alternative Triggers.” IRT’s letter to GNSO Council regarding privacy IRT Discussion

Next Steps Revise the policy languages to reflect the changes and distribute to IRT for final review Finalize policy documents for both CL&D and Transition policies and publish them on 1 February 2017 with the announcements of the effective dates Plan and execute the policy implementation Next IRT Meetings: 14 February 2017 Monthly scheduled and adjusted as needed Meeting schedule is maintained on the Thick Whois IRT Community Wiki space

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