domain contacts: person vs role (1.Viewing)

Maybe [notify]richard.schreier[/notify] or [notify]FM[/notify] can shed some light on a question I've always had.

When it comes to the varlous fields in WHOIS data that identify a person, I've always had the understanding that you are not allowed to use a "role" and that you must list a real person's name. So you cannot list the name as something like "Domain Admin" instead of "John Doe".

Clearly the "Registrant Name" should be accurate for the selected CPR category type, otherwise you're risking losing the domain in a RIV when you cannot prove your name is "Domain Admin" or whatever.

However, when it comes to admin/tech/billing contacts, I can understand where a company might prefer to name a role such as "Domain Administrator" or whatever, as employees may come and go.

Is that allowed by CIRA?

You [notify]rlm[/notify] are correct that registrant contact names should be accurate for selected CPR category. Having incorrect information does risk losing the name in a Registrant Information Validation (RIV) process. The admin contact has the same rights/access to the domain as the registrant. In both cases, our policies define both the Admin Contact and the Registrant as a “Person: means a natural person, partnership, limited partnership, limited liability partnership, corporation, limited liability corporation, unlimited liability company, joint stock company, trust, unincorporated association, joint venture or other entity or governmental entity” (Ref: https://www.cira.ca/policy/legal-agreement/registrant-agreement). Any registration that uses an invalid “name” in the Registrant or Admin Contact records risk losing the domain.

Ultimately CIRA needs to be able to verify the registrant is who they say they are and that they indeed comply with the CPR category they have chosen. A good example where this becomes problematic is where a privacy proxy is used (remember that all individual registrant data is redacted in whois by CIRA and always has been so privacy services simply hide the registrant from us). In these cases, "officially" the privacy service is the registrant which causes issues when we need to validate compliance or when the domain is subject to legal action.

[notify]richard.schreier[/notify], thanks for the response. That definitely brings up a few more questions. I'll tackle them one issue at a time though. First one up:

OK, so in theory that sounds as if both the Registrant and Admin contacts are allowed to be listed with the company name, thus not needing to list a personal name? So for example, would the following domain be fully meeting CIRA's policies?

Domain Name: roulette.ca
Registry Registrant ID: 14313861-CIRA
Registrant Name: 0979592 B.C. LTD.
Registrant Organization:
Registry Admin ID: 24802844-CIRA
Admin Name: 0979592 B.C. LTD.
Admin Organization:

From my experience, it appears that a Registrant Name is allowed to be something other than a natural person, but that an Admin Name is required to be a natural person. Then admin's organization might optionally be listed in the Admin Organization field, as in this example:

Domain Name: google.ca
Registrant Name: Google LLC - TMA868122
Registrant Organization:
Admin Name: Lauren Johnston
Admin Organization: Google LLC

This could of course be entirely due to each registrar having different implementations for creating a new contact. I'm pretty sure I've been forced down this road by certain registrars where I couldn't put my company name in the "Admin Name" field, they were requiring a real person's name. The also would not allow me to select the same "Registry Registrant ID" in place of the "Admin Registrant ID". They require choosing a separate Admin ID. However, Tech and Billing contacts were allowed to use the same Admin ID.

But it does appear possible to assign the Registrant ID to the Admin ID, as in this case:

Domain Name: theblack.ca
Registry Registrant ID: 90399170-CIRA
Registrant Name: Wang Rui
Registrant Organization:
Registry Admin ID: 90399170-CIRA
Admin Name: Wang Rui
Admin Organization:

So, just to be clear here, from CIRA's perspective, it is perfectly acceptable to have the Registrant ID be used as the Admin contact too, right?

Thanks!