How You Can Help
KnujOn will begin featuring serious policy issues here that the public can participate in changing and improving.
One of the reasons we have so much chaos in the Registrar community is because of secrecy and a lack of
public accountability. There are at least 100 Registrars currently using "mail drop" addresses or post office
boxes for their disclosed location.
KnujOn found 70 Registrars with no disclosed location at all.
Dozens of Registrars claim to be in one country but are really in another.
KnujOn has also found registrars with false or incorrect address information in their own Whois records.
The hidden
ownership of some Registrars has also caused considerable controversy when eventually disclosed.
At the core of this problem is the fact that
ICANN doesn't require registrars to publicly disclose their place of incorporation. We have trouble
finding any other industry (ones that involve so much importance and trust) where this type
of obfuscation is a standard practice. Furthermore, it seems somewhat hypocritical for
registrants to be required to enter accurate registration data when the same
is not expected of the Registrars collecting that data.
In order to assist ICANN achieve its stated goal
of transparency and accountability, we propose a modification to the
Registrar Accreditation Agreement (RAA), the core contract ICANN uses to issue
certifications to Registrars. A review of the RAA is currently underway and KnujOn is seeking the following
language (or equivalent) be added to the RAA:
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"All Accredited Registrars must submit main office location, including country,
to be publicly disclosed in ICANN web directory. Post Office boxes, Incorporation addresses,
and mail-forwarding locations will not be acceptable.
Registrars must also provide for public display the name of CEO or President.
ICANN must be notified within 30 days of a location or presiding officer change.”
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This is suggested language. Any version that addresses the issues discussed above and meets
the requirements of public disclosure.
If you wish to support this proposal, please write a brief and polite email as an Internet user
to raa-consultation@icann.org expressing
your concern of the lack of public Registrar disclosure and request that the new
version of the RAA include a section requiring owner and location disclosure. You may
use the suggested language above, your own version, or simply a personal statement of concern over
the issue.
Suggested Letter
To: raa-consultation@icann.org
Subject: Ending Registrar Secrecy in RAA
Dear ICANN RAA Consultation Staff,
I am writing to you to request a change in the Registrar Accreditation Agreement that will improve transparency and accountability. It has come to my attention as an Internet user that there is no requirement in the standard Registrar contract to that requires public disclosure of Registrar ownership or location. I am concerned that this loophole in the agreement opens the door to fraud, secrecy and consumer abuse. Please consider adding the following language or equivalent to the RAA:
"All Accredited Registrars must submit main office location, including country, to be publicly disclosed in ICANN web directory. Post Office boxes, Incorporation addresses, and mail-forwarding locations will not be acceptable. Registrars must also provide for public display the name of CEO or President. ICANN must be notified within 30 days of a location or presiding officer change.”
Without public disclosure there cannot be true transparency, accountability or trust. I appreciate your consideration.
Sincerely, YOUR NAME
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