C21. Describe in detail your proposed methods of providing registry services on an equivalent basis to all accredited registrars having registry-registrar agreements in effect. Your description should include any measures intended to make registration, technical assistance, and other services available to ICANN-accredited registrars in different time zones and relevant languages. In addition, describe the Registry Code of Conduct and other commitments you propose to make to ensure that all such registrars receive equivalent access to registry services. In preparing your response to this item, you may wish to refer to Appendices H and I of the registry agreements ICANN has entered into for the unsponsored TLDs.
RegisterOrg Will Offer:
1. Outreach to registrars
2. Assistance to registrars
3. Robust, secure registry system
4. Equal registrar access
5. Internal neutrality audits
6. An independent entity
Register.com believes that no registry can optimally function without the support, trust, and confidence of its sponsoring registrars and the DNS community as a whole. Register.com has established RegisterOrg as a separate company, committed to operating the .org registry as a trusted, neutral third-party provider of registry services. Moreover, RegisterOrg will develop responsible policies and mechanisms for ensuring that the registry best serves the public interest.
RegisterOrg understands and respects the significance of creating a level playing field for all .org-sponsoring registrars by providing equivalent access to the .org registry. As described in detail below, RegisterOrg will ensure equivalent access to the registry and technical assistance, regardless of a registrar’s time zone or language.
1. Outreach to Registrars
In the event that RegisterOrg is selected to operate the new .org registry:
1. The Registry will immediately send a letter to all currently authorized .org registrars, informing them of the appointment of a registrar-relations support team and providing them with the contact liaison who will facilitate all future communications.
2. The Registry will adopt a simple and uniform registrar-accreditation process, providing consistency to all registrars while making it easier for new registrars to participate as .org sponsoring registrars. The process will require registrars to provide an accreditation application; execute the Registry-Registrar agreement; and, optionally, technical testing and certification to verify that the registrar is appropriately accessing the registry’s systems.
3. Upon the execution of the .org registry agreement with ICANN, RegisterOrg will immediately send all ICANN current .org-sponsoring registrars a copy of the new registry-registrar agreement, along with registrar toolkits, including a marketing toolkit featuring the Registry’s marketing plans, product positioning, research, and a technical toolkit (described below) including information regarding access protocols and technical testing information.
4. The Registry will likewise encourage and support other registrars that may choose to sponsor .org through the simplified accreditation process and by publicly providing copies of the registry-registrar agreement (as well as the Registrar Toolkits) as soon as it is available.
2. Assistance to Registrars
Through its registry services division, Register.com already enables registries of all sizes to take advantage of its new state-of-the-art systems. Register.com’s advanced and reliable infrastructure allows registries to offer their clients near real-time domain name resolution, advanced Whois capabilities, 24-7 customer support, and online client management applications.
RegisterOrg will provide additional assistance to registrars by having a dedicated Registrar Relations team (see .org employee chart in Section II) and assigning each registrar a liaison who will be responsible for managing the relationship and all associated questions. The Registrar Relations staff will be equipped to accommodate applicable registrar time-zones and language requirements.
To further support registrar operations, the Registry will create a Registrar Extranet that supports multiple languages on the .org registry Web site for all registrars. The extranet will provide basic information about becoming a sponsoring registrar, as well as a secure Web-based portal that will be accessible to all sponsoring registrars. The portal will be equally accessible only through passwords or logins provided by the Registry, and will contain pertinent information like new developments and relevant policy or technical issues, such as planned outages.
The portal will also provide self-help services for registrars, including:
· Knowledge bases;
· Frequently asked questions;
· Downloads of SRS client software; and
· Support for e-mail messaging.
Customer Service Plans
RegisterOrg will provide customer service and technical support to registrars 24-7 to accommodate the global nature of the .org domain-name registration business. Register.com currently provides this level of support to its registry clients. Thus, Register.com has already established mechanisms (apart from its core registrar business) that can accommodate and support registrars. In the event that the .org registry is delegated to RegisterOrg, such systems will serve the Registry.
To interact with the Registry in the most responsive manner, each .org-sponsoring registrar will be asked to identify its own employee Registry contact. The contacts will be assigned unique passwords for phone calls into the customer support center, and their e-mail addresses will be securely stored on file. The customer support center will only accept and respond to email inquiries from these predetermined email addresses. Additionally, individuals may be required to verify their identities by providing password information when contacting the customer support center. In this way, the Registry will support the needs of registrars participating in the system and can provide assurance that it is addressing questions and concerns raised by sponsoring registrars.
Just as Registry Advantage, RegisterOrg’s tech provider, currently provides its ccTLD clients with a high level of timely, efficient support through its registry services division, the .org Registry will provide registrars with central help-desk support via telephone and the Web-based portal. To ensure responsiveness to registrars, especially those located in different geographic regions, the Registry operator will establish a ticketing system and a schedule that will set forth average callback and resolution timeframes.
In order to assist registrars in connecting to the SRS, the Registry will provide a registrar toolkit (RTK). The RTK is a software development kit that will support the development of a registrar software system for registering domain names within the registry using the RRP. The RTK will consist of both software and documentation elements.
Although the specific components of the RTK are subject to change, the initial makeup of the toolkit will include:
· Documentation describing the details of both EPP and RRP protocols;
· Documentation describing the registry’s registration policies;
· Documentation relating to RegisterOrg’s customer service, including contact and escalation information;
· C++ libraries, providing registrars with an API;
· Java libraries, providing registrars with an API;
· Documentation describing the APIs and their use; and
· Sample code, providing registrars with an example of how to make use of the APIs and perform various functions in the SRS.
The Registry technology provider currently offers toolkits for both its EPP and proprietary SRP interfaces. These toolkits will form the basis for the RTKs provided to registrars, although some modifications will need to be made to reflect the specific requirements and policies of RegisterOrg; also, RegisterOrg will create some additional software and documentation to support the RRP interface to the SRS.
In order to make the transition from RRP to EPP as straightforward as possible, the Registry’s technical team will provide additional documentation during the transition. The documentation will describe the differences between the protocols, and will attempt to make the APIs for both protocols as similar as is practical. The Registry will also interact with the registrar community, in order to discover whether any additional software or documentation would make the transition more straightforward.
The RTK can be used by the registrar as a basis for connecting to the Testing Environment, Support and Training (TEST) environment (see below), and can be used to develop a system for interfacing with the live registry once the registrar has been certified. The RTK will remain under continuous development and will provide support for additional features as they become available—including other platform and language support.
A marketing toolkit featuring an aggressive .org re-positioning strategy will be provided to all registrars with a revitalized marketing program. Most importantly, this toolkit will endeavor to help registrars attract the target markets – people, causes and ideas – through a defined positioning of .org, with a clear brand, unlike what exists today. The program will be geared to reinvigorate the registrar channel and empower them to push the .org domain name through their existing channel as well as new ones. Highlights of the toolkit include:
· Co-marketing programs: RegisterOrg will propose a co-promotion marketing program whereby registrars are able to effectively target new customers;
· Sales and promotion materials: The registry will create highly attractive and effective sales and promotion materials, including print, radio, email, trade show advertising and publicity materials, (Please see appendix C)
· Sample graphics for use on resellers’ web sites,
· Content rich web pages to include on their web sites, and
· Sample proposed emails to send to their customers.
Throughout the transition, and on an ongoing basis, the Registry will provide registrars with access to the Testing Environment, Support and Training (TEST) systems, which allow them to test their SRS client implementations in an environment that is functionally identical to the live SRS. The TEST systems will provide registrars with both RRP and EPP interfaces, allowing them to fully test both legacy systems as well as systems that will connect to the new EPP interface.
3. Developing a Robust, Secure, Shared Registry System
To enable registrars to interface with RegisterOrg’s shared registry systems, the Registry will use the protocols described in C22 that are being developed by Register.com’s registry services team. The shared registry system will support an unlimited number of competitive registrars and provide equivalent access to all registrars for the purposes of registering, transferring or updating domain name registrations.
4. Equivalent Access by All Registrars
As the first registrar in the market after government deregulation in 1999, Register.com recognizes the fundamental significance of ensuring that DNS resources are administered in a fair, efficient, and neutral manner that makes them available to all parties desiring to provide DNS services. Register.com assures that in the event ICANN designates RegisterOrg as the .org registry operator, it will at all times be operated as a trusted, neutral third-party provider of registry services.
To that end, the .org Registry will adhere to a Code of Conduct (described below) that ensures fair and equivalent treatment of all .org registrars, current and future. Moreover, in light of Register.com’s interest in the .pro TLD, which finalized its agreement with ICANN this May, Register.com has already implemented mechanisms designed to ensure fair access, confidentiality of data and other sensitive information, and to establish an organizational conflict of interest avoidance plan.
The Code of Conduct set forth below is based upon the existing ICANN unsponsored TLD agreements, in particular Appendix I of these agreements, which creates a framework that institutes fair access to registry services as well as confidential treatment of registrar data. Moreover, Register.com will commit to adhering to all relevant policies and procedures that are outlined in Appendix H and I.
.org Registry Code of Conduct
i. All ICANN-Accredited Registrars in the .org Registry shall have equivalent access to those Registry Services operated by RegisterOrg.
ii. The .org Registry and its shareholders and subcontractors shall not in any way attempt to warehouse or register domain names in their own right, except for names designated for operational purposes.
iii. Any shareholder, subsidiary, affiliate, or other related entity of the .org Registry that also operates as a provider of registrar services shall maintain separate books of account with respect to its registrar operations.
iv. Neither the .org Registry nor its owners, subsidiaries, affiliates, or other related entities shall have access to user data or proprietary information of an ICANN-Accredited Registrar, except on an as needed basis for registry management and operations.
v. The .org Registry will ensure that no user data or proprietary information from any ICANN-Accredited Registrar is disclosed to its affiliates, subsidiaries, or other related entities, except as necessary for registry management and operations.
vi. Confidential information about the .org Registry business services will not be shared with employees of any DNS registry operator or ICANN-Accredited Registrars, except as necessary for registry management and operations. Employees with any such access will be required to receive organizational conflict of interest training, certify compliance and sign non-disclosure agreements (as set forth in the section below).
Other than in connection with the distribution of dividends or other profits to the Registry’s members and shareholders, or incidental benefits that might arise from public information regarding the .org Registry, the Registry will not directly or indirectly show any preference or provide any special consideration to any ICANN-Accredited Registrar in the .org Registry versus another ICANN-Accredited Registrar in the .org Registry, as those terms are defined by ICANN, including the registry or registrar owned by a shareholder of the .org Registry.
Additional Policies and Practices
The Registry will also adhere to the policies and practices detailed in Appendices H and I of ICANN’s unsponsored TLD Agreements, including:
· The Equivalent Access Policy, established in the unsponsored TLD Agreement, Appendix H. The Equivalent Access Policy provides that all ICANN-Accredited Registrars will have the same access to Registry Services, using equivalent protocols, limitations, and security measures;
· The Access to Data Policy, which will include a nondisclosure agreement to be signed by employees, officers, directors, vendors, etc., as well as detailed best practices;
· Procedures for Protection of Proprietary Information, which detail how sensitive or proprietary information should be safeguarded, labeled and utilized; and
· An Organizational Conflict of Interest Compliance Plan.
5. Audits and Reporting to Ensure Code of Conduct Compliance
RegisterOrg will conduct internal neutrality reviews of itself and all subcontractors on a regular basis. In addition, the Registry and ICANN may mutually agree on an independent party that ICANN may hire to conduct a neutrality review of the Registry and its subcontractors to ensure that the Registry, any subcontractors, and its owners are in compliance with the Code of Conduct.
To bolster confidence in the registry and earn the public trust, the Registry will also provide public reports regarding the code of conduct and equivalent access six months (6) following the effective date of the .org Registry Agreement, and each subsequent six-month (6) period thereafter. RegisterOrg shall certify to ICANN that it is providing all ICANN-accredited registrars with equivalent access to the Registry.
6. Adoption of An Organizational Conflict of Interest Compliance Plan
In the event that the .org registry is delegated to RegisterOrg, Register.com will institute a detailed Organizational Conflict of Interest (OCI) plan that will, among other things, maintain its own financial accounting systems, have independent employees with fiduciary responsibility to the registry occupy separate business premises, and maintain confidentiality of registry’s sensitive and other proprietary data. We believe that the OCI plan will not only provide registrars with assurance about Register.com’s commitment to provide each registrar with equivalent access, but also its commitment in training employees and staff with regard to the importance of its role as the registry operator.
Included in the OCI plan are the following baseline requirements:
1. Independence for all .org Registry employees, providing in pertinent part that the staff will be recruited from the open market and will have fiduciary duties to the Registry, not its shareholders. All employees will be required to enter into agreements to protect proprietary and sensitive registry information. Until the Effective Date, all officers and employees will be seconded to the registry from the founding shareholders. Thereafter, all fulltime employees recruited to the operation will have a fiduciary duty to the Registry, not to its shareholders.
2. Financial Separation of the Registry, including a requirement that separate financial statements are prepared using United States GAAP accounting standards. Such financial statements will account for the Registry’s own costs, revenues, cash flow, etc. as a separate entity, using distinct systems and accounting functions. Reasonable and independently auditable internal accounting controls will be in place to ensure the adequacy of these systems and functions. The accounting and operational procedures will be established in such a fashion that no detailed customer account information relating to any individual ICANN-Accredited Registrar will be available to any other ICANN-Accredited Registrar.
3. Separate business premises than any other ICANN-Accredited Registrar.
4. Physical Barriers, which will limit access to the Registry by non-Registry employees.
5. Nondisclosure agreements, which will protect sensitive or proprietary data.
6. Staff Training of all Registry personnel, as well as other employees who have a need to know Registry business. The formal training will introduce employees to OCI and will provide the staff members with a clear understanding of Registry Policies, particularly the Equivalent Access Policy and the staff members' responsibility under the plan. OCI training will be required before any potential staff member is given an assignment or access to Registry material. OCI refresher training will be given on an annual basis.
7. Written annual certification, by each employee, demonstrating his or her compliance with the OCI training.
8. The Registry’s General Manager will, in all cases, ensure that the Registry and its employees do not release any information to any ICANN-Accredited Registrar, or their respective employees that could be used by an ICANN-Accredited Registrar to the detriment of any other ICANN-Accredited Registrar regardless of the official stated sensitivity of the information. Under no circumstances will Registry Sensitive Information be approved by the General Manager for release to any other ICANN-Accredited Registrar.