First Registration Directory Service Review

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The First Registration Directory Service Review (RDS1), also known as the first WHOIS Review, was conducted between 2010 and 2012, with implementation of improvements continuing through December 2016.[1] [2] 43 - Costa


The Affirmation of Commitments, an agreement between ICANN and the United States Department of Commerce, establishes ICANN's obligations to perform its duties with specific commitments in mind. All of the commitments bear on public and consumer trust of the organization. ICANN is to perform its functions in a manner that:

  • ensures accountability and transparency of decision-making;
  • preserves the security, stability, and resiliency of the DNS;
  • promotes competition, consumer trust, and consumer choice; and
  • enables access to registration data.

ICANN is also charged to periodically review and assess its performance through the lens of each of the above commitments.[3]

ICANN's board enshrined these commitments (and the associated reviews) in its Bylaws in Article 1 (Mission, Commitments, and Core Values)[4] and in Article 4 (Accountability and Review).[5] Article 4.6 deals with "Specific Reviews," each of which are tied to one of the commitments in the Affirmation of Commitments.[6]

The Organizational Effectiveness Committee of the board oversees the conduct of specific reviews.[7] The RDS is one such review. The Affirmation of Commitments specifies that RDS reviews should be carried out by volunteers from among the community, as well as "experts, and representatives of the global law enforcement community, and global privacy experts."[8]

Initiating Steps

An initial call for volunteers was issued on June 1, 2010.[2] To assist in selection and recruitment, the GNSO, ALAC, and SSAC all submitted screening requirements for volunteer applicants.[9]

The additional requirements of the Affirmation of Commitments prompted the review team to issue a second call for volunteers, specifically addressing independent experts, members of the law enforcement community, and global policy experts.[10]

Process and Findings

The review team's planning process identified three topic areas for inquiry and research:

  1. Clarity of WHOIS Policy;
  2. Existing laws, privacy issues, and the use of anonymized or proxy WHOIS information; and
  3. ICANN's compliance and enforcement activities.

The team created an "other issues" placeholder in the event that the community or further investigation raised additional issues.[11]

The review team created subteams to contextualize and investigate these issues and the specific questions raised in the Terms of Reference document.[12] In addition, the review team issued an RFP for research into consumer trust in WHOIS.[13] UserInsight was selected for the consumer survey. The team also conducted a survey of law enforcement officials regarding WHOIS policy and access to necessary information.[14]

The collected findings of the RDS1 team, along with recommendations for improvement, were submitted in a draft report on December 5, 2011.[15] Thirty-five comments were submitted, including a large number of individual comments.[16] ICANN 43 was held just as the comment period was closing, and the WHOIS Review was a topic of both cross community meetings and work sessions.[17]

Final Report and Implementation

Building on public comments to the draft report, as well as comments at ICANN meetings and the consumer trust survey, the RDS1 team submitted its final report on May 11, 2012[18] The report contained sixteen recommendations connected to the findings of the review team, with five central themes:

  • ICANN should make WHOIS Policy a strategic priority:
    • craft a single WHOIS policy;
    • improve outreach;
    • create a detailed and comprehensive plan regarding implementation of report recommendations; and
    • report annually on status and progress of implementation.
  • ICANN should ensure that its compliance efforts conform to best practices.
  • ICANN must improve WHOIS data accuracy (multiple recommendations).
  • ICANN should improve data access:
    • implement regulations for WHOIS privacy/proxy services; and
    • overhaul InterNIC to improve usability.
  • ICANN should implement changes to WHOIS to accommodate internationalized domain names.

The ICANN Board acknowledged receipt of the report on June 23, 2012, and instructed the ICANN org to make recommendations regarding implementation of the recommendations.[19] Public comment on the report was largely positive.[20] In November 2012, the Board acted on the final report by requesting an issue report on "the purpose of collecting and maintaining gTLD registration data, and on solutions to improve accuracy and access to gTLD registration data," with the intention of initiating a GNSO PDP on the topic.[21] At the time, the GNSO was already engaged with its "thick WHOIS" policy development process. The board also reaffirmed its commitment to enforcement and compliance efforts around registration data.[21] The board provided a summary of proposed actions on the recommendations of the report; in most cases, ICANN staff were directed to implement recommendations related to the improvement of existing policies and the continued negotiation of terms in the context of the New gTLD Program and other initiatives.[22]

The final implementation report of RDS1 was issued in December 2016, marking implementation of all recommendations as complete.[1]