How to respond to a Whois Data Problem Report sent by ICANN?

As per an ICANN advisory relating to Whois Accuracy Requirements See details, Registrars are required to ensure that Registrants correct their domain name's Contact Details, within 15 days of receiving a complaint from the Sponsoring Registrar. Failure to comply with this requisite, empowers (but not necessarily requires) the Registrar to cancel/delete the domain name registration.

Sample Whois Data Problem Report mailed by ICANN to the Registrar's WDRP Email Address

Subject: domainname.com -- Whois Data Problem Report
From: WDPRS@internic.net
Reply-To: WDPRS@internic.net
To: Registrar Email Address

Dear Registrar,

Please find below here a report concerning inaccurate Whois data for domainname.com.

As a reminder, ICANN-accredited registrars are obligated to take reasonable steps to investigate and correct reported Whois inaccuracies <https://www.icann.org/registrars/ra-agreement-17may01.htm#3.7.8>.

As indicated in the following Registrar Advisories, registrars have a vital role in maintaining the accuracy of Whois data:

Registrar Advisory Concerning Whois Data Accuracy
<https://www.icann.org/announcements/advisory-10may02.htm>

Registrar Advisory Concerning the "15-day Period" in Whois Accuracy Requirements
<https://www.icann.org/announcements/advisory-03apr03.htm>

Please note that you are not obligated to reply directly to ICANN or to the person who submitted this report, but ICANN does monitor registrar handling of these reports to ensure compliance.

Thank you for your attention, and for your anticipated cooperation.

Please contact ICANN's Registrar Liaison Department if you have any questions.

Best regards,

InterNIC Whois Data Problem Reports System

================================================================

Domain: domainname.com
Submitted: 2007/01/09 17:41:36

Registrar: Registrar Name
Reporter Name: Some Name
Reporter Email: postmaster@somedomainname.com
Reporter IPAddr: 97.98.99.100

Errors in Registrant Information:

Name:INCORRECT
Phone:INCORRECT
Description:
Known criminal operation
Victim of identity theft (Registrar, please contact)

Address is not deliverable
Phone number is not functional/incomplete
Yahoo TOS forbids use of yahoo email service for registering domains. Yahoo has been notified.

Explanation:
Known criminal operation
Illegal drug sales
Identity Theft and Credit Card Fraud ring.

================================================================

WHOIS INFORMATION AS OF 2007/01/09 17:41:36

REGISTRAR WHOIS:

Registration Service Provided By: Reseller Name
Contact: +1.8889990000
Website: https://www.resellerbrand.net

Domain Name: domainname.COM

Registrant:
Company Name
Name (email@address.com)
Address
City
State,00000
US
Tel. +1.7778889999

Creation Date: 26-Dec-2006
Expiration Date: 26-Dec-2007

Domain servers in listed order:
ns2.hebeticbob.com
ns1.uiltonthe.net
ns2.ferrywend.com
ns1.renedrop.com

Administrative Contact:
Company Name
Name (email@address.com)
Address
City
State,00000
US
Tel. +1.7778889999

Technical Contact:
Company Name
Name (email@address.com)
Address
City
State,00000
US
Tel. +1.7778889999

Billing Contact:
Company Name
Name (email@address.com)
Address
City
State,00000
US
Tel. +1.7778889999

Status:ACTIVE
The data in this whois database is provided to you for informationpurposes
only, that is, to assist you in obtaining information about or related to a
domain name registration record. We make this informationavailable "as is",
and do not guarantee its accuracy. By submitting awhois query, you agree
that you will use this data only for lawfulpurposes and that, under no
circumstances will you use this data to:(1) enable high volume, automated,
electronic processes that stress orload this whois database system
providing you this information; or(2) allow, enable, or otherwise support
the transmission of massunsolicited, commercial advertising or
solicitations via fascimile,electronic mail, or by telephone. The
compilation, repackaging,dissemination or other use of this data is
expressly prohibited withoutprior written consent from us. The registrar of
record is Registrar Name. We reserve the right to modifythese terms at
any time. By submitting this query, you agree to abideby these terms.

REGISTRY WHOIS:

Whois Server Version 1.3
Domain names in the .com and .net domains can now be registered with many
different competing registrars. Go to https://www.internic.net for detailed
information.

Domain Name: domainname.COM
Registrar: Registrar Name
Whois Server: whois.registrarname.com
Referral URL: https://www.registrarname.com
Name Server: NS1.RENEDROP.COM
Name Server: NS1.UILTONTHE.NET
Name Server: NS2.FERRYWEND.COM
Name Server: NS2.HEBETICBOB.COM
Status: clientTransferProhibited
Updated Date: 02-jan-2007
Creation Date: 26-dec-2006
Expiration Date: 26-dec-2007

>>> Last update of whois database: Tue, 9 Jan 2007 16:16:24 EST <<<

NOTICE: The expiration date displayed in this record is the date the
registrar's sponsorship of the domain name registration in the registry is
currently set to expire. This date does not necessarily reflect the
expiration date of the domain name registrant's agreement with the
sponsoring registrar. Users may consult the sponsoring registrar's Whois
database to view the registrar's reported date of expiration for this
registration.

TERMS OF USE: You are not authorized to access or query our Whois database
through the use of electronic processes that are high-volume and automated
except as reasonably necessary to register domain names or modify existing
registrations; the Data in VeriSign Global Registry Services' ("VeriSign")
Whois database is provided by VeriSign for information purposes only, and
to assist persons in obtaining information about or related to a domain
name registration record. VeriSign does not guarantee its accuracy. By
submitting a Whois query, you agree to abide by the following terms of use:
You agree that you may use this Data only for lawful purposes and that
under no circumstances will you use this Data to: (1) allow, enable, or
otherwise support the transmission of mass unsolicited, commercial
advertising or solicitations via e-mail, telephone, or facsimile; or (2)
enable high volume, automated, electronic processes that apply to VeriSign
(or its computer systems). The compilation, repackaging, dissemination or
other use of this Data is expressly prohibited without the prior written
consent of VeriSign. You agree not to use electronic processes that are
automated and high-volume to access or query the Whois database except as
reasonably necessary to register domain names or modify existing
registrations. VeriSign reserves the right to restrict your access to the
Whois database in its sole discretion to ensure operational stability.
VeriSign may restrict or terminate your access to the Whois database for
failure to abide by these terms of use. VeriSign reserves the right to
modify these terms at any time.

The Registry database contains ONLY .COM, .NET, .EDU domains and
Registrars.

Registrar: Registrar Name
Whois Server: whois.registrarname.com

Process to be followed by the Registrar upon receiving a Whois Data Problem Report from ICANN

Upon reviewing the complaint, try to identify the nature of the issue reported by the complainant. Typically, the following 2 types of complaints are seen more often:

Complainant has indicated that the Contact Details are Inaccurate: Considering that as a Registrar, there are no means available with yourself to verify each address, it is recommended to simply admit the complaint and initiate due diligence to get the Registrant to validate their address.
Complainant has indicated that the Contact Details are Inaccurate and the domain name is involved in some form of Abuse: Apart from processing the domain name for Whois Inaccuracy, you would need to take additional steps to end any abuse emanating from the domain name(s).

To Process a Whois Inaccuracy Complaint

Login to your Control Panel. See details
Search for the domain name and click on the domain name to reach the Order Details view See details.
Under Order Information, check if Privacy Protection displays Enabled or Disabled.
If Privacy Protection is enabled, disable See details it and in the reason specify the ICANN Whois Inaccuracy Complaint number.

Respond to the Complainant and ICANN that Privacy Protection for the domain name(s) has been disabled. Also indicate that the Complainant in the future may use either the Contact Domain Owner or the Report Abuse form at https://privacyprotect.org/ if the domain name indicates PrivacyProtect.org as the Company Name.
If Privacy Protection is disabled, send a Warning email to your Customer (and mark a copy to your Sub-Reseller, if any). This mail should contain the following information:
- The domain name(s) for which a complaint has been received.
- The current Whois output of the domain name(s) as displayed on your Registrar Whois Server.
- The content of the received complaint without mentioning the Complainant's and ICANN/InterNIC's details.
- The specific Contact Details that you want the Customer to correct.
- The Knowledgebase link See details that the Customer can refer to, to modify his Contact Details.
- Specify that if the concerned Contact Details are not modified within 15 days, the said domain name(s) would be Suspended.
- Provide your FAX Number/Email Address where the Customer can send you a signed letter on the Letterhead of that Contact confirming that the concerned Contact Details are accurate. This letter should be accompanied with the accurate Contact's Proof documents, like Driving License, Passport, Military ID, etc..
- Remind the Customer that as per the Registrar Registrant Agreement for Domain Names 2. (1), the Customer needs to always maintain updated Contact Details for all domain names registered through Registrar <your Registrar Name>.
  
  Let the Customer know that he can obtain a copy of this Agreement within their Control Panel from Help -> Legal Agreements.
Respond to the Complainant and ICANN that a Whois Inaccuracy complaint has been processed for the domain name(s) and you have requested the Customer to correct the inaccuracy within 15 days or else the domain name(s) would be Suspended.
If the Customer does not modify the concerned Contact Details within 15 Days, then the Registrar should Suspend the domain name.
Note
- The Reason that you mention in your Reseller Control Panel while Suspending the domain name should ideally indicate:
  - Why this domain name has been Suspended? Preferably mention the ICANN Complaint number for ease of relating.
  - When and/or how you contacted the Customer before to correct the inaccuracy?
  - Where they may contact you to get assistance regarding this issue?
  Additional Information
  Suspend / Unsuspend a Domain Name
- While ICANN allows the Registrar to cancel/delete the domain name registration in such cases, it is recommended to only Suspend such domain names, as it allows Customers a chance to get back their domain name by ensuring that they provide you accurate details along with sufficient verifiable proof.
Upon Suspending the domain name(s), update the previous email thread while updating both the Customer as well as the Sub-Reseller (if any), that the domain name(s) is/are being Suspended after 15 days since sending the Warning to correct the Whois Inaccuracy.

Note
Ensure that you again provide your FAX Number/Email Address where the Customer can send you a signed letter on the Letterhead of that Contact, confirming that the concerned Contact Details are accurate. This letter should be accompanied with the accurate Contact's Proof documents, like Driving License, Passport, Military ID, etc..
Respond to the Complainant and ICANN that since the Customer did not pay heed to your request to have the Whois inaccuracy corrected within 15 days of the complaint, the domain name(s) have been Suspended.

To Process a Abuse as well as Whois Inaccuracy Complaint

Apart from following the above process, you should perform the below mentioned steps depending upon the type of abuse being perpetrated from a domain name:

Spam: Use the Spam Processing Tool See details to process a spam complaint.

While the system would email, the Complainant about the action you have taken for the spam complaint, you would need to respond to the email sent by ICANN indicating the action taken on the spam complaint.
Phishing, Child Sexual Abuse Material, Virus/Malware, Money Laundering Scam: In all such cases, it is recommended to Suspend a domain name, only after collecting evidence of such abuse.

Since you would be Suspending the domain name itself, there is no need to follow-through the entire Whois inaccuracy process. Your response to ICANN and the Complainant should indicate that you are Suspending the domain name after confirming that such abuse does exist.

Note
The reason for Suspending the domain name should indicate the ICANN complaint number and the type of abuse the domain name was involved in.

Additional Information
Suspend / Unsuspend a Domain Name