Use of proper names for Administrative and Technical contacts

[msn]

I consult for a company which manages a portfolio of domains for customers - domains in the UK, China, Germany, Peru, Ireland, India, you name it, including Canada - and for just about all of the various registrations they have a Role Contact Record as the Billing, Administrative and Technical contacts, except Canada.

As an example, the billing contact could look like this:

Billing contact: Renewal Accounts renewal.accounts@thecompanyname.com

Depending upon who is working on a certain day, a different person might be doing the renewals and it is easier for them to have all those messages arrive in one account.

But CIRA demanded we use proper names - the actual name for a designated person - rather than a role name where a message may be handled by one of a number of people. That means we need to use one name, even when that means this person then has to forward the message to the proper one.

So I was peeved to find out that other companies are using role contacts at CIRA without any problem at all:

Registrant name: Universal Properties Corp.

Administrative contact
Name: Domain Librarian
Postal address: 829 Southgate Drive
Guelph ON N1G 4W6 Canada
Phone: 5198357585
Fax:
Email: parkingpartners@upc360.com

Technical contact
Name: Domain Librarian
Postal address: 829 Southgate Drive
Guelph ON N1G 4W6 Canada
Phone: 5198357585
Fax:
Email: parkingpartners@upc360.com


So who is right here? If we could update our contacts like this it would make things much easier.

[CanSpace]

The official policy is that you must use a proper/real name for the admin and technical contacts. You can certainly specify something like above, but if/when they find out they will demand you change it.

[Maxwell]

I can't speak on CIRA's behalf, but properly titled individuals must be named under the applicable categories of CIRA's whois records.

In cases such as your client's, let's say there are three people in IT who all work part time, and whoever is on duty at a moment when a CIRA related email comes in must oversee the task. We'll call these guys Bob One, Bob Two and Bob Three. Let's assume that out of them, Bob Two is the superior individual.

I would then label the whois record as having Mr. Bob Two as the contact, but set up an email address to the effect of "cirainbox@example.com", which then gets forwarded to bobone@example.com, bobtwo@example.com and bobthree@example.com.

Even though other companies get away with it, that sure doesn't make it OK.

[Gerry]

So in instances where these "rules" are not applied, what are the consequences?

And who within CIRA has the time or resources to check each registration?

Enormous challenges and time consuming to catch, report, and enforce each instance.

[msn]

That is an excellent question. I have reported a number of domain name registrations to CIRA where the registration clearly would have to be deleted if it were owned by you, but the big interests seem to slip through.

As to the costs, CIRA is scrambling to find a way to blow through the $14.8 million dollars it has taken in over the last 12 months, and to avoid lowering the wholesale cost of registrations, which really goes against the original concept of having CIRA in the first place, so it has the money, if it was required, but it is not.

Like ICANN, CIRA has a compliance system: if one finds an inaccurate registration or one which is not compliant, you simply go to the form here and fill in the information.

If the person looking at the contact form deems it worthy, it goes to the 'compliance team' and this may be a roadblock too.

A compliance person pushes that down into the relevant registrar, and they go to their registrant with the information request, which then is passed back up the chain. It does not require much effort, but does necessitate the CIRA people being willing to actually follow what is in the registration agreement and enforce its terms.

We are going to submit around 100 such issues to CIRA, having documented the details, and go back over these to find out the results, after which it will become a real topic of interest.

So in instances where these "rules" are not applied, what are the consequences?

And who within CIRA has the time or resources to check each registration?

Enormous challenges and time consuming to catch, report, and enforce each instance.

[mogtnomr]

I tried the role contact name like "domain administrator" many years ago, but was told by cira (via my registrar) to fix it or lose it...

[msn]

We saw the same thing, and yet other registrants seem to be able to ignore that for years now.