Thank you. Adam >This would be the final draft, to be sent to the Task Force and GNSO. >Note that the only dissent is recognized in the statement. (sec. 2) > >===== > >Statement of the Noncommercial Users Constituency on Whois Task Force >1/2 Recommendation: >Improving Notification and Consent for the Use of Contact Data in the >Whois Service > >1. Constituency position >Noncommercial domain name users welcome efforts to ensure that domain >name registrants are better informed about the publication of their >private contact information via the Whois system. Public, anonymous >access to private contact information poses a number of risks to >registrants and may violate their rights to privacy. Until this >situation is reformed, conspicuous notification is essential. > >The text we reviewed contains an error. Under point 3, the sentence >"Registrars must obtain a separate acknowledgement from registrars that >they have read and understand these disclosures" should read >"Registrars >must obtain a separate acknowledgement from _registrants_ that they >have read and understand these disclosures." > >NCUC strongly supports the requirement to set aside the notification >and to require a distinct and separate acknowledgement from registrants >that they are aware of the exposure of their private information. We >observe, however, that for customers registering multiple domain names >in the same transaction, only one such acknowledgement should be >required. The constituency would like to make sure that the same >notification and acknowledgement should take place during renewals. > >We strongly support the statement "The wording of the notice provided >by registrars should, to the extent feasible, be uniform." Because of >the highly competitive nature of the registrar business, registrars have >an incentive to downplay or obscure the privacy implications of >registering a domain name because they fear it may deter customers from >signing up. The specific wording of the notification, therefore, should >not be left to the discretion of registrars. We suggest that the wording >be developed by staff subject to the approval of the GNSO Council, and >translated as literally as possible into different languages by an >independent party. This language should then be incorporated into the >Registrar Accreditation Agreement. > >2. Method for Reaching Agreement on NCUC position > >NCUC's Chair drafted and circulated via email a constituency >statementon its discussion list, soliciting input from its members. A >minor addition to the draft, concerning renewals, was suggested and >agreed and incorporated into the constituency statement. All comments >were supportive except for one, which emphasized the additional burden >on registrants of the additional process. > >3. Impact on Constituency. >While there is some recognition that the registration process might be >slightly more complicated as a result of the proposed change, all member >organizations but one considered the benefits of more prominent >notification and registrant awareness to outweigh any burden. > > > >Dr. Milton Mueller >Syracuse University School of Information Studies >http://www.digital-convergence.org >http://www.internetgovernance.org