[APAC-Discuss] (DRAFT) ALAC Statement on Translation and Transliteration of Contact Information in Response to Working Group Input Request from SO/AC

[Rinalia Abdul Rahim]

Dear Colleagues,

A draft ALAC statement has been posted on the Charter questions posed by
the Translation and Transliteration of Contact Information Working Group on
this wikipage:

https://community.icann.org/display/alacpolicydev/At-Large+Translation+and+Transliteration+of+Contact+Information+Working+Group+SO-AC+Input+Request+Workspace?focusedCommentId=47257011#comment-47257011

The draft is provided as a basis for discussion.  Please note that you need
to log-in to enable the comments feature of the wikipage.  If you cannot
log-in for whatever reason, please send your comments to staff (
staff at at-large.icann.org) and they can help you.

The draft statement is pasted below for a quick review so that you can
decide whether or not to comment via the wiki.

Best regards,

Rinalia


 *(DRAFT) ALAC Statement on Translation and Transliteration of Contact
Information in Response to Working Group Input Request from SO/AC*



 (Note:  The use of the word "transformation" of contact information
pertains to the "translation and / or transliteration" of contact
information.)


*(1) Whether it is desirable to translate contact information to a single
common language or transliterate contact information to a single common
script*

It is important to note that translating contact information to a single
common language privileges the users of that language over other users,
just as the transliteration to a single common script privileges users of
that particular script over others.  The choice of one single common
language or script does not reflect or support a global Internet community,
which is diverse in language and script use.

Our preference is to have registration contact information in languages and
scripts that reflect the diversity of Internet users.

We believe that it is unreasonable to assume that registrants will be able
to enter contact information in scripts or languages other than their local
script and language.  It is possible that some registrants may have the
ability to do so, but in principle registrants should not be expected or
required to transform their own contact information.

In terms of the choice of whether to translate or transliterate contact
information, the transformation of contact information to a level where it
is understandable to users of registration data may require a combination
of both.  For example, when transforming contact information, proper names
or nouns (i.e., unique names of persons, places, events and things) should
not be translated and should instead be transliterated.



*(2) What exactly the benefits to the community are of translating and/or
transliterating contact information, especially in light of the costs that
may be connected to translation and/or transliteration?*

The Internet has a global user base.  Transformed contact information that
is validated to be accurate and useable allows users worldwide to see who
are the domain name registration holders and how to contact/reach them.

Contact information is used for various purposes by a range of users.  The
purposes include regulatory/contract enforcement, domain name monitoring
and research, domain name purchase/sale, individual Internet use, technical
issue resolution, legal action, abuse mitigation and malicious Internet
activities (see Expert Working Group on gTLD Directory Services Report).

In cases where harmful Internet activities are perpetrated, the
availability of transformed contact information that is accurate and
useable facilitates those taking action to protect end users.

Moreover, transformed contact information that is validated for accuracy
and usability promotes consumer trust in the Domain Name System and is
beneficial to the At-Large community.



*(3) Should translation and/or transliteration of contact information be
mandatory for all gTLDs?*

Based on the principle that gTLDs serve global Internet users,
transformation of contact information should be mandatory for all gTLDs.



*(3) Should translation and/or transliteration of contact information be
mandatory for all registrants or only those based in certain countries
and/or using specific non-ASCII scripts*

If transformation of contact information is to be implemented as a matter
of policy, then it should be mandatory for all registrants for the purpose
of serving global Internet users.

Registrants based in countries and / or using specific non-ASCII scripts
should not be discriminated against in the implementation of contact data
transformation.  Contact information for registrants in ASCII script should
also be equally transformed for the benefit of non-ASCII script users.



*(4) What impact will translation/transliteration of contact information
have on the WHOIS validation as set out under the 2013 Registrar
Accreditation Agreement?*

No comment.



*(5) When should any new policy relating to translation and transliteration
of contact information come into effect?*

No comment.



*(6) Who should decide who should bear the burden translating contact
information to a single common language or transliterating contact
information to a single common script? This question relates to the concern
expressed by the Internationalized Registration Data Working Group (IRD-WG)
in its report that there are costs associated with providing translation
and transliteration of contact information. For example, if a policy
development process (PDP) determined that the registrar must translate or
transliterate contact information, this policy would place a cost burden on
the registrar.*

The decision on who should bear the burden of transforming contact
information should be informed by the views of and impact on all affected
parties, which would include the provider of the information (registrants),
those involved in collecting and maintaining the information (i.e.,
registrar, reseller, registry) and the range of users that include end
users and regulatory authorities/law enforcement agencies.

The PDP decision-making rules and procedures for Consensus Policy should
apply with input from all ICANN Advisory Committees (i.e., At-Large
Advisory Committee, Governmental Advisory Committee and Security and
Stability Advisory Committee).



*(7) Who does your SG/C believe should bear the cost, bearing in mind,
however, the limits in scope set in the Initial Report on this issue?*

In determining who should bear the cost, it would be important to consider
whether the transformation of contact information is made for general use
or specialized use.

If the transformation is required for general use, the cost should be borne
by the process/entities that collect the information.  If the
transformation is required for specialized use, the parties requiring the
specialized service should bear the cost of contact information
transformation.

If transformation has general use and is crucial for particular specialized
use, then a sharing of costs between those collecting the information and
those requiring specialized use of the information could be considered.



END