[nc-deletes] Comments from NCC representative (constituency statements)

[Adam Peake <ajp@glocom.ac.jp>]

As anticipated during the task force teleconference of November 15, 
it has not been possible for the non-commercial constituency to 
develop a position statement in response to the issues raised in the 
task force issues paper, terms of reference, etc. The NCC membership 
was asked for comments, there was some discussion, but not yet enough 
to help form the basis of a  draft position statement. I doubt the 
constituency will be in a position any time soon to submit a 
substantive position statement on the deletes issue.

However, comments to the constituency mailing list, personal email, 
and conversations in Shanghai, show a common concern is the lack of 
clarity and consistency in the renewal/deletes process.  Anxiety 
around deletions generally might be much reduced if the process were 
better understood. In small, often poorly resourced organizations, 
lack of awareness seems to be a likely cause of poor internal 
processes for managing names, maintaining contact details, etc.

(ONE)  Summarizing and interpreting general comments received:

i./  Registrants need to be given clearer information about the 
renewal process at the time of registration.

At the time of registration, it should be made clear that names are 
not bought outright, but must be renewed after a period of time. It 
should be made clear that if contact information given to the 
registrar changes, it must be updated or reminders about renewal may 
not be received and the name perhaps deleted/lost. Correspondence 
from the registrar rather than information on a website would be the 
most effective way to educate the registrant.

ii./  Clarity in all correspondence about the renewals process is important.

At a time when Internet users must to wade through a mailboxes full 
of spam, a not insignificant amount of which touts cheap domain name 
registrations, registrars should be careful to present renewal 
notices in a straight forward manner, uncluttered by excessive 
marketing information and other perhaps off-putting information. 
Plain language, on subject, should be the basis of renewal 
correspondence.

Suggestion:

It is not ICANN's (or DNSO's) place to dictate how any business 
should write letters, or generally communicate with its customers. In 
this industry self-managing regime, providing clear information about 
the renewal process should be part of industry best practise. A best 
practise document might require registrars to present a minimum set 
of information about the renewal process to registrants at the time 
of registration (minimum requirements that would not prevent 
registrars from offering "better" terms as a way to differentiate 
their product.) And offer advice on standard formats to be considered 
when corresponding about renewal.


(TWO) Issues 1 and 2 of the deletes issue paper (Issue 1:  Uniform 
delete practice after domain name expiry by registrars; Issue 2: 
Deletion following a complaint on WHOIS accuracy.)

In-line with comments on clarity and consistency above, a uniform 
deletion process is desirable. Whether the result of a complaint on 
WHOIS accuracy (however the WHOIS Task Force defines this) or the 
result of usual expiry, uniformity is helpful to registrants. That 
is, the instruction to delete a name for WHOIS inaccuracy would be in 
effect the same as reaching expiry date, i.e. the first day of the 
auto-renew period (up to 45 days) and should be followed by 
redemption grace. Exceptions are envisaged (some have been noted by 
other members of the deletes task force), but, generally, the average 
registrant should be able to expect consistent treatment.

Note.  While the above statement on uniform practises has been 
supported by some representatives of the constituency, and has been 
put to the constituency a number of times, it has not received 
substantive public comment. It would be inappropriate to take "no 
comment" as acceptance at this stage. So the above is offered as a 
sense of the constituency rather than statement.

The message will be sent to the non commercial constituency 
discussion list. I hope NCC members will comment.  Given sufficient 
feedback from the constituency, a revised statement will be submitted 
to the task force.

Thank you.

Adam

Adam Peake
GLOCOM Tokyo

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