28 Abuse Prevention and Mitigation
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Next we will detail how we will promote proper conduct under the registry and try to avoid abusive behavior and unacceptable registrant behaviour. We will address the topics:
- Promotion of WHOIS accuracy
- Special REBATE WHOIS accuracy promotion
The following mechanisms will be implemented to avoid abusive registrations and unacceptable registrant behavior.
1) Launch phases (Gradual Offering Plan): As stated before the registry will implement a Gradual offering plan that seeks to fairly assign domains to their rightful owers.
- Sunrise: As mentioned ealier a Sunrise phase will be implemented to grant privileged accesss to Registrants representing valid Trademarks as per the Sunrise policies implemented.
- Landrush: For Trademarks that do not qualify for the sunrise phase and for individuals with interests in strings that are not protected by Trademarks the Landrush phase will allow a period for the assignment of domains not in a first come - first served basis.
2) Resolution policies adopted: Registry will adopt Resolution policies as per ICANN indications
- URS: The Uniform Rapid Suspension process will be implemented by the Registry to allow for rapid takedown of abusive regsitrations.
- UDRP: The UDRP will be adopted and Registrars will be required to comply to any and every determination made by the administrative entity handling any UDRP process.
Alternative use of Rapid Takedown Dispute Resolution Policies: In the absence of URS, the Registry may provide a Rapid Takedown process through engagement with a dispute resolution provider that consists of a response team of qualified expert (qualified UDRP panelist). The Registry agrees that majority of cases that go through the Uniform Dispute Resolution Process (UDRP) are mainly obvious variant of well-known marks. As such, it would be a waste of time or resources for the most obvious cases of infringement to go through the UDRP filings. Registry may provide a rapid takedown process where a response team of qualified experts (qualified UDRP panellists) will be involved to determine within 48 hours of receipt of a short and simple claim of involving a well-known mark or otherwise inherently distinctive mark and a domain name where no conceivable good faith basis exists. The results may result in an immediate termination of the domain name, but will not prejudice either party’s election to pursue other dispute mechanisms.
3) Abuse point of contact: Registry will prominently publish abuse contact information on its website; The abuse contact will prominently displayed on its webpage, and a uniform naming convention will be utilized to facilitate discovery of the website; The abuse contact information shall consist of telephone and email address. The email address may be an alias, not a specific person’s name, to manage operational efficiency; Request submitted by verified law enforcement agencies to this contact will receive an acknowledgement of receipt from the registry within 24 hours; and
The contact at the registry will be empowered to act in response to a well-founded report of illegal, criminal or malicious activity involving any domain name registration.
4) Other mechanisms: As required be ICANN Registry will comply to the Trademark Notice Notification service. This service will be implemented for the first 60 days after general availability is open. The service will be fully provided by the Registry and the Registrars need not to worry about the implementation of the notices. In addition to this, we will implement a special mechanism to encourage accurate WHOIS data. The mechanism will be explained further in this answer.
The following resources will be employed by the Registry to avoid abusive registrations and unacceptable registrant behavior.
- Compliance executive: The project manager of the extension will assume the roles of an executive Compliance officer. This role will be in charge of:
a) Receiving any abuse complaint on domains under the extension.
b) Serve as the point of contact for any issues regarding processes like URS and UDRP. The Compliance officer will also execute decisions regarding the policies.
c) Engage with outside providers for the internal monitoring of sites and monitoring of phishing or pharming activities.
d) Track and monitor the takedown of abusive registrations and sites involved in illegal activity such as phishing of pharming.
e) Participate and engage with ICANN regarding all compliance requests and policies to be implemented.
*Compliance officer will be in charge of setting up a single point of contact with information at the Registry website.
*Compliance officer will be bound to a SLA as described later
Registrar policy: Registry will also demand that an abuse point of contact be present at all accredited registrars and serve for:
a) Receiving any abuse complaint on domains under the extension.
b) Serve as the point of contact for any issues regarding processes like URS and UDRP. The Compliance officer will also execute decisions regarding the policlies.
- Other resources that may be needed by the Registry to implement the proposed mechanisms will be assigned from the actual operations team as per pragmatic requirements. At least one operations executive will be in charge of supervising the correct applications of the mechanisms and engaging with the Compliance officer to solve any issues.
Pursuant to the RRA, the Registry reserves the right to deny, cancel, or transfer any registration or transaction, or place any domain name(s) on registry lock or hold, in its discretion, with the aim to:
- Protect the security and stability of the DNS;
- Comply with any applicable court order, laws, government rules and requests of law enforcement;
- Comply with any dispute resolution process;
- Comply with the terms of Registration Agreement;
- Avoid any liability, civil or criminal, on the part of the registry, as well as its affiliates, subsidiaries, officers, directors and employees;
- Correct mistakes of the registry or any registrars with regards to domain registration.
The Registry reserves the right to place upon registry lock, hold or similar status a domain name during resolution of a dispute.
Registrar policy: Registrar will be required to have terms and agreements with every registrant that strictly state what constitutes abusive behaviour, restricts the same, and clearly states remedies available as mitigation to such behavior.
- The Registry intends to incorporate Anti Abuse Use Policy into the Registry Registrar Agreement (RRA). Registrars should not tolerate abusive use related to domain names for which they act as sponsoring registrars.
- Under the provision of the Registry Registrar Agreement, Registrar shall promptly investigate complaints alleging any such abusive practices, and shall take all appropriate actions based upon such investigations. Registrar shall use commercially reasonable effort to resolve the complaints, as request or recommended by the registry or any legal authority.
- Registrar’s failure to comply with the policy shall constitute a material breach of the RRA, and shall give rise to the rights and remedies available to the registry under the RRA.
Reseller policy: Registrar will be required and bound by the Registrar agreement to represent any Reseller as if the actions of the Reseller were made by the Registrar itself. Registrar will also be required to have terms and agreements with every reseller that strictly control and instruct policies in the case of abusive registrations.
Joining Working Groups: To keep up with knowledge in dealing with anti-abuse issues and mitigation practises, The Registry intends to participate in Anti-Phishing Working Group (APWG). The APWG is the global pan-industrial and law enforcement association focused on eliminating fraud and identity theft that result from phishing, pharming, and email spoofing of all types. The APWG also focuses on policy-related issues associated with the DNS to examine abuses of the DNS that may require remediation. The Registry may also tap into the forum of Registry Internet Safety Group (RISG). The purpose of RiSG is to facilitate dialogue, affect change, and promulgate best practices to combat domain name abuse, Internet identity theft in all its forms and malware distribution. The member registry operators are examining anti-abuse best practices and use cases for registries, and opportunities for data sharing.
All other policies as instructed by ICANN and as found relevant to reduce abusive behaviour and Registrations.
Promotion of WHOIS accuracy:
Several elements will be put in place for the promotion of WHOIS accuracy under the extension. Next we will name and describe each of the elements.
1) Registry-Registrar Agreement: The Registry-Registrar Agreement will have in place clauses that require that Registrants deliver and maintain up to date information about the WHOIS information for domain names. These clauses must be present in the Registrar agreement, in any Registrant agreement and in any Reseller agreement.
1b) Regular Monitoring of Registration Data for Accuracy and Completeness : Registrars will be required to email with a reminder of registrant´s obligation to keep WHOIS data accurate as per WDRP. The Registry will rely on the WHOIS Data Reminder Policy (WDRP) set down by ICANN for the accredited registrars to ensure the WHOIS data of all domain names are at least reviewed once a year for accuracy. The email will include the actual WHOIS data and instructions to update the information.
2) Thick Registry: The implementation of the Registry will be a thick Registry and therefore the Registry will have information on the Registrants as provided by the Registrar. (Except of registrations with proxy data)
3) Registrars will be required by the registry to undertake reasonable steps whenever there is a report of inaccurate information in WHOIS.
Special REBATE WHOIS accuracy promotion mechanism:
The Registry will promote whois accuracy by a proprietary mechanism described next:
- A random selection of registrants not using PROXY services will be emailed with a request to verify email and phones provided.
- For the verification, a link in the initial email will be sent to the email provided as the regsitrant email. The link in the email must be clicked to verify the accuracy of the email delivered. This click will take the registrant to the Registry controlled validation site.
- For the verification of the phone number a text message, or an automatic call will be sent to the registrant phone number once the link in the first email has been clicked. The text message will include a PIN number that must be entered in the registry controlled site.
This data will allow us to know the estimate the accuracy of the WHOIS database and will allow us to actively participate in ICANN´s debate arount the enforcement of WHOIS infomation.
Specific topics on abuse prevention and mitigation
Management of orphan glue records: The Registry does not allow orphan glue records. Glue records are removed when (or required to be removed before) the delegation point NS record is removed. Other domain names that need the glue record for correct DNS operation may become unreachable or less reachable depending on their settings of DNS service.
What constitutes abusive behaviour: The Registry does not tolerate the abusive use of its domain name, which causes security and stability issues for the registry, registrars and the general Internet community. The Registry defines abusive use as the wrong use of power, position or ability. Abusive behavior will be any act done by any registrant that were to violate the rights of any other person or legal entity, in any jurisdiction, whether it were by the sole act of a registration of a domain or by the usage given to the same for the publishing of content or its use for communicative purposes. Abusive behavior includes but is not limited to the following:
- Illegal or fraudulent actions;
- Any form of spam i.e. email spam, messaging spam etc;
- Phishing which involves the use of bogus websites to obtain personal information;
- Pharming which involves redirecting unknowing users to fraudulent websites to obtain personal information;
- Willful dissemination of malware;
- Fast-flux hosting which involves the use of DNS to frequently change the location of a website to hide its location or host illegal activities; and
- Botnet command and control.
SLA for resolution of abuse complains: Registry will comply to timing as indicated in Dispute Resolution policies adopted by ICANN.
1. Participating in Uniform Rapid Suspension (URS)
The Registry will cooperate with ICANN for the implementation of URS, shall the policies and procedures are finalized. The involvement of the registry for the scope of URS shall include the following:
- Upon completion of the Administrative Review, the URS Provider will immediately notify the registry (via email) (“Notice of Compliant”) after the Compliant has deemed compliant with the filing requirements. Within 24 hours of receipt of the Notice of Complaint from the URS Provider, the registry shall “lock” the domain name, meaning the registry shall restrict all changes to the registration data, including transfer and deletion of the domain names, but the name will continue to resolve. The registry will notify the URS provider immediately upon locking the domain name (“Notice of Lock”).
- If after the Examination in Default case, the Examiner rules in favor of the Registrant, the URS provider shall notify the registry. Upon receiving the official notice from the URS provider, the registry will unblock the name and return full control of the domain name registration to the Registrant.
- If the Determination is in favor of the Complainant, upon receiving the official decision from the URS provider, the registry will suspend the domain name, which shall remain suspended for the balance of the registration period and would not resolve to the original web site. The nameservers shall be re-directed to an informational web page provided by the USR Provider.
2. Service Level for responding to law enforcement requests
In responding to law enforcement requests, the Registry will use the provision within the Anti-Abuse Domain Use policy to act quickly to take down sites that are harboring malware, launching phishing attacks, or otherwise being used to launch attacks across the Internet.
3. The following internal SLAs will also be enforced:
- Reply to an abuse claim: 12 hours
- Communication to all related parties of any abuse complain: 12 hours
- Compliance to any instructions given by Administrators panellists of other authorized personnel: 36 hours
Resource and Operation Plan
As this issue is heavily related to policy, resources constitute only means of executing the proposed mechanisms. For the implementation the following resources will be available:
- Compliance officer
- Operational executive (support)
These two persons will manage implement and track the execution of the proposed Abuse Mitigation measures.
- Registry team has run for almost 3 years Domain Registration Services that have been very successful in Colombia and in more than 10 countries around the world. Registry team will be comprised of experienced executives in the domain registration business from Central Comercializadora de Internet (ICANN Accredited Registrar). Resources are on hand for all the non technical operations of the Registry. On hand operational non technical resources for this task include:
- Project manager (Compliance officer)
- Operational executive (One of the two support specialists)
These resources are currently part of the team that runs Central Comercializadora de Internet (ICANN Accredited Registrar).
Resource activity plan:
As this task is strictly related with policy it will be the Registry team that will be in charge of this aspect.
From the Registry side, Project manager, support specialists, and Technical Leader will handle issues related to administrative control, non technical relationship with Registrars, relationship with ICANN, relationship with providers such as Qinetics, Policy monitoring and Management, etc. Registry team will fulfill all of the tasks and activities detailed above.
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