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Trust and Assurance

Policy > Public Comment > Trust and Assurance

CURRENT STATUS: CLOSED FOR REVIEW

Discussed at Vancouver Pilot Consultation (May 20, 2009) and Sydney Regional Consultation (June 25, 2009). Posted to Round 1 30-day Online Consultation (August 10th, 2009)

DESCRIPTION

This policy outlines how trust and accuracy will be maintained for the global Dot Eco Community.

1. ADOPTION OF GOVERNING PRINCIPLES

All Dot Eco registrants will be required to commit to upholding the Dot Eco Governing Principles as part of their registrant use agreement.

2. CONTACT INFORMATION

In order to ensure that the information provided in Dot Eco is correct and up-to-date, it is important that a person responsible for the eco profile be identified when registering the domain.

A. Dot Eco System Disclosure Contact Person
All registrants will be required to provide information (name and valid email address) of a contact person responsible for maintaining the domain's eco profile. This is akin to current standard procedure of identifying Technical and Administrative contacts for any domain.

Contact information:

  • Should be updated yearly, or in the case of any changes.
  • Will not be made public and will not be displayed in the Dot Eco System unless the registrant elects to display the information.

Questions for Discussion

  1. Are there any privacy concerns associated with this policy? If so, what are the and how might they be addressed or mitigated?
  2. Should Big Room Inc. require contact information to be provided on an yearly basis?

3. REGISTRATION PROCEDURES

On registering a Dot Eco domain name, the name will be held for the registrant while the the required elements of the eco profile are completed.

  • Registrants will have a set time period (10-30 days) in which to complete their eco profile.
  • If the required profile information is not provided within that time period, Big Room Inc. will first contact the registrant directly via email with a warning period (5 days).
  • If no eco profile information has been provided within the allotted time period, the registration will expire.

Questions for Discussion

  1. What is an appropriate time period for registration to ensure registrants have adequate time to provide quality disclosure information?
  2. Should an extension period be made available in the case that a registrant needs more time? If so, for how long?
  3. How can we minimize gaming of the disclosure system and time period?
  4. Can the same registrant repeatedly register the domain after it has lapsed, and how do we control for this?

4. OPTIONAL THIRD-PARTY ASSURANCE OF DOT ECO PROFILES

Some registrants may want to demonstrate best practice by having a third-party auditor verify their eco profile.

Within the Dot Eco System:

  • Registrants will be given the option to display that their disclosure has been verified by a third-party auditor and the name of the audit organization.

Questions for Discussion

  1. Should auditors be accredited? If so, under what system?
  2. Should the audit be conducted annually, or at will?

5. ASSURANCE COMMITTEE

An independent Assurance Committee will be created that will report to the Dot Eco Stakeholder Council and Big Room Board of Directors. This committee will have responsibility for overseeing the trust and quality assurance policy, developing best practice standards for ensuring data accuracy. They may resolve selected disputes from the audit or whistle-blower facility that cannot otherwise be normally resolved.

  • The Committee will be made-up of a diverse group of stakeholders drawn from the Dot Eco Community.
  • Selection will consider region, expertise, and type of entity (NGO, company, government, individuals).
  • The Committee's by-laws, meeting minutes and decisions will be publicly available.
  • The Committee 's meetings and discussions will be moderated by an independent third party professional facilitator contracted by Big Room.
  • If updates or changes to the rules of the Committee are made, all registrants will be immediately notified.
  • The decision making process will be open, transparent and accountable to the Dot Eco community.
  • A annual report of actions taken will be produced by the Committee.
  • Committee members will volunteer their time, but will reimbursed by Big Room Inc. for travel expenses associated with attending Committee meetings.

Questions for Discussion

  1. Should the Committee be paid for their time?
  2. How should members of the Committee be selected?
  3. What areas of expertise should be expected?
  4. How often should they meet to reasonably cope with the workload and respond to complaints in a timely manner?
  5. How long should the term be for individual Committee members?
  6. What conditions might result in Committee members being asked to step-down from their role?

6. ANNUAL NAMESPACE AUDIT

To ensure ongoing compliance to the Governing Principles of Dot Eco, an annual random audit of Dot Eco names and disclosures will be made by an independent accredited auditor.

  • Big Room Inc. will contract an independent third party to perform an annual random audit of a percentage of Dot Eco profiles.
  • The methodology and scope of this audit will be defined by the third party, with the objective of maximising accuracy in the Dot Eco namespace and System.
  • Depending on the nature of the findings, further investigation practices will be referred to Big Room Inc., a separate independent auditor, or the Assurance Committee.

Questions for discussion

  1. What should be the scope of the random audits
  2. What percentage of domain names should be audited in any one year to insure high rates of compliance?

7. INVESTIGATION PRACTICES

A whistle-blower (complaints) facility will be established in addition to the annual audit wherein members of the Dot Eco Community can flag problematic disclosures in the Dot Eco System.

The whistle-blower facility will enable complaints to be lodged by members of the Dot Eco Community about registrants in Dot Eco.

  • Each Dot Eco disclosure page will have a link where false or spam disclosures can be reported to the Facility. (ie. "Flag this")
  • Authors of complaints will be required to submit a valid contact email address to make a complaint
  • The contact information of authors of complaints will be held in strictest confidence. The email address provided will be soley to communicate with the author about the complaint.
  • Responses to complaints will depend of the nature and type of complaint being registered.
  • Registrants found to be either falsely or incorrectly presenting disclosures will be notified by email that they are being investigated and the reason for that investigation.
  • Further investigation will be made by an independent contracted auditor who can initiate take-down procedures if warranted.
  • If the auditor determines that the complaint is not addressed by an existing policy, complaints will be referred to the Assurance Committee and to the independent Disclosure Committee for a review of Policies.
  • All complaints will be documented and made public in an annual report by the independent auditor.
  • The annual report will provide an analysis of overall patterns of complaints, and describe the actions taken by the auditor, Big Room Inc. or the Assurance Committee.

Questions for Discussion

  1. Might requiring an email address cause difficulties for the complainant?
  2. What types of complaints might we expect in the whistle-blower facility?
  3. Which complaints should be reviewed as priorities?
  4. Should complaints made be visible on the disclosure page of the subject entity?
  5. Will the complaint mechanism as currently structured prevent inappropriate use?

8. PENALTIES

One result from an investigation by Auditors or the Assurance Committee could be a recommendation that the domain be suspended and/or taken-down.

  • Registrants found to be either falsely or incorrectly presenting disclosures will be notified by email that they are being investigated and the reason for that investigation.
  • Registrants will have an initial 30 day period to explain and/or rectify their breach.
  • During this period the website will still be active.
  • During this period a notification will be posted on the Dot Eco disclosure page that an investigation is in effect.
  • Following no response or a response deemed inadequate, the auditors will recommend to Big Room Inc. that the site be taken down.
  • Following an investigation resulting in an inadequate response take-down decision, the registrant can lodge an appeal with the Assurance Committee.
  • While such an appeal is in process, the website will be held (suspended) until a final decision is made.

Questions for Discussion

  1. What should be the criteria for accepting whether or not an adequate response to the investigation has been made?
  2. Should the website be suspended during an appeal following an investigation? Should there be a time limit set to that?

9. APPEAL MECHANISMS

At any point during the investigation or take-down period, registrants will have the ability to file an appeal with the Assurance Committee.

10. NAME DISPUTES AND TRADE MARK PROTECTIONS

Big Room Inc. will strive to protect the rights of existing trademark owners, and work actively to minimize any negative impacts on them by:

  • Launching a sunrise period wherein existing trademark owners can register domain names.
  • Referring all disputes between parties over the rightful ownership of domain names to the ICANN Uniform Domain-Name Dispute Resolution Policy (UDRP) or other such body or mechanism as sanctioned by ICANN.

Note: Big Room has contracted Laga/Deloitte, a leading IP protection expert in the Domain Industry, to ensure a do-no-harm approach to trademark owners. We welcome comments in this regard.