Friday, 28 November 2014

Nominet being strange

[update: see Nominet reply in comments]

I know, silly title, especially related to Nominet address checking. Anyone that deals with Nominet will be used to them being a tad strange.

However, we had a somewhat surreal conversation with them yesterday over a domain we were registering.

To put it in to context, Nominet are now trying to ensure the registrant details for domains are "correct". This is part of the new .uk level domain registration process. However, checking details are "correct" is not simple! It kind of brings me back to my discussions on "legal entities", but more so.
  • A domain could be registered by someone anywhere in the world (though a UK service address is needed for .uk domains). The rules on "legal entities" and means to check those vary from country to country. It would be almost impossible for Nominet to check many of these.
  • Even just considering the UK, an individual does not have to be traceable. I.e. it is quite valid for a registrant to not be on the electoral role; not have any utility bills in their name,; not have a driving licence; and not have a passport, especially if young and living with parents. Even so, they still are a perfectly "valid" person with a perfectly "valid" UK address. The only real way to check such details is to post something to the address and check it arrived. I have no idea if Nominet do that.
  • There are, of course, various other types of legal entity that could be more complex, but most come back to the issue with an "Individual" who is responsible, so the same problem as above.
  • However, there is one type of registrant for which it is very very simple: UK registered companies. A UK company has a name, company number, and service address that are all public record and available to be checked from companies house on their web site. Checking the basic details for a UK registered company is very simple.
What happened is that we created a new company and registered three domains (.co.uk, .org.uk, and .uk). Opening up .uk just means paying for yet one more domain when you make a company. However, they were flagged by Nominet as invalid!

Alex called Nominet. They confirmed on the phone that he was the contact (checked name and email used), and he checked and confirmed that he had not mistyped the company number, name or address and that Nominet had all of the right details. The guy on the phone was happy to sort this out whilst on the phone, yay!

He did explain that Nominet do not have a direct link for checking companies and as it was a new company then that is why it was flagged as invalid. That, in itself, seems odd as I am sure companies house have such services. Indeed, register a company, and you have spam post the next day from people that use such services. Why don't Nominet have a proper link in to companies house?

Anyway, this is then where it got a tad odd. Having confirmed that this is, indeed, as per the registration details recorded, a UK limited company; and that the company name, number, and address were right, you would think that would be the end of it. It means Nominet can check the details independently at companies house - something that takes seconds.

But no...

First off he asked Alex to email a reply, while on the phone, with a link to the details on companies house. This seems odd - and time consuming - compared to just typing an 8 digit number in to their web site. It is also slightly open to abuse as Alex could have sent a link that looked like companies house but was not. However, if you have ever used the companies house web site then you will know that the details for a company are not on a simple link / URL.

At this point, if it was me, I would have emailed http://companieshouse.gov.uk/ to him and said click company information and type the company number... But Alex carefully explained the inability to do a direct URL.

So the guy from Nominet then insisted that what Alex does is take a screen shot, put it in a pdf and email it.

WHAT?!?!?! [a phrase I am having to type rather a lot on my blog lately]

What exactly would he do with this screen shot? Surely the only possibly thing he could do is check it. The only way to check it is to go to the companies house web site, type the company number, and see that it looks the same, having checked the screen shot matches the registered details for the domain. Surely it would save time and effort for all to just do that in the first place. Of course, if he is not going to do that, then Alex could, very easily, fake the screen shot.

Alex explained all of this, but to no avail. A screen shot had to be emailed!

It does remind me of RIPE who have the same problem, and wanted a copy of the company certificate for something. They eventually accepted a screen shot of companies house (which could have easily been faked, just like a certificate). At least RIPE have the excuse of being in a different country and so perhaps not knowing how UK companies work.

Well done Nominet - you have unlocked the achievement [Pointless extra bureaucracy]

13 comments:

  1. I've just had to deal with Nominet about a domain that was suspended because they couldn't validate me.

    They had created an account on their system for the email address attached to the domain for my but I couldn't do anything with it until I actually contacted them separately.

    The fact is the registrars don't even know Nominet's policy, tucows require the name and address proof to be linked. Nominet state that it is not required.

    There's also a major privacy concern, how happy would you be to upload a copy of your driving license or passport to a 3rd party server?

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  2. When you say "Not a simple URL" do you mean one like this?

    http://business.data.gov.uk/id/company/03342760

    or equivalently but not guaranteed not to move:
    http://data.companieshouse.gov.uk/doc/company/03342760

    The full daily Companies House feed costs quite a lot of money. I very much doubt that Nominet (who make diddly from having such a thing unlike those spam advertisers) would want to buy that feed. Quarterly feeds are cheaper, but will obviously not have a brand new company the day after it's registered.

    However if all you need to do is check a company still exists and has a specific registered address - as you see you can machine generate a URL for the company from its company number.

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    Replies
    1. I never knew of such a direct link and have not seen that when using CH. Where did you find it?

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    2. This particular type of URI is documented here:

      http://www.companieshouse.gov.uk/about/miscellaneous/URI.shtml

      It's part of the general work of "open data" in government. A lot of data about a wide variety of things (e.g. where schools are, who reports to who within the government and its agencies, which medicines are approved for prescription on the NHS) is published online now and there is somewhere a central catalogue although I can't remember right now where it is. Sorry.

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  3. Hi.

    This was an oversight on Nominet's behalf for which we apologise. We should have checked the Companies House website during the call and verified the details that way. Our customer service team have been reminded of the correct process this morning.

    Thanks.

    Phil Spray.

    Nominet.

    ReplyDelete
  4. Nice reply - hopefully Phil will help Nominet to get their policies in a sensible shape and train the staff.

    The goal of keeping .uk clean is laudable but needs to be clever.

    Start by suspending spammers...

    ReplyDelete
    Replies
    1. Whilst I dislike spammers as much as you, you do need to remember that a domain registration is nothing to do with "the way the domain is used". Nominet are not, and should not be, an enforcement of "internet police". The role simply of ensuring accurate registration details as publc record does the job or allowing those that are responsible for enforcement to pursue that more effectively.

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    2. > Nominet are not, and should not be, an enforcement of "internet police".

      The problem is that Nominet genuinely think they are, and act as though, they are the "UK Internet police"

      I recently had an address validated for addresses which my business vacated more than three years ago and customers who have had addresses rejected even though I have been physically sat within that address with them when putting the registration request through to Nominet.

      > The role simply of ensuring accurate registration details as publc
      > record does the job or allowing those that are responsible for
      > enforcement to pursue that more effectively.

      Nominet are far far worse than that:

      http://ktetch.co.uk/2014/06/which-uk-internet-company-hates-your-privacy-the-most-heres-a-contender/

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  5. Ah, the voice of reason from RevK.

    Well then, there should be a government office commissioned to be in charge of 'data' and they should make laws to stop spammers then enforce them.

    ReplyDelete
    Replies
    1. Oddly there is all of that except the actually enforcing anything part...

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  6. I'm a tad uncomfortable with spamming being unlawful. I have an email address; why should it be unlawful for people to send stuff to it?

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    Replies
    1. If you are an individual subscriber and the email is unsolicited marketing then yes, is is simple unlawful.

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    2. I suspect Alan's question was a "why is it illegal?" rather than an "is it illegal?" question?

      Alan — if you have not seen it, the reasoning behind the EU laws on electronic spam, from which the UK law derives, is contained in recitals 40 - 42 of the privacy and electronic communications directive (2002/58/EC):

      "(40) Safeguards should be provided for subscribers against intrusion of their privacy by unsolicited communications for direct marketing purposes in particular by means of automated calling machines, telefaxes, and e-mails, including SMS messages. These forms of unsolicited commercial communications may on the one hand be relatively easy and cheap to send and on the other may impose a burden and/or cost on the recipient. Moreover, in some cases their volume may also cause difficulties for electronic communications networks and terminal equipment. For such forms of unsolicited communications for direct marketing, it is justified to require that prior explicit consent of the recipients is obtained before such communications are addressed to them. The single market requires a harmonised approach to ensure simple, Community-wide rules for businesses and users.

      (41) Within the context of an existing customer relationship, it is reasonable to allow the use of electronic contact details for the offering of similar products or services, but only by the same company that has obtained the electronic contact details in accordance with Directive 95/46/EC. When electronic contact details are obtained, the customer should be informed about their further use for direct marketing in a clear and distinct manner, and be given the opportunity to refuse such usage. This opportunity should continue to be offered with each subsequent direct marketing message, free of charge, except for any costs for the transmission of this refusal.

      (42) Other forms of direct marketing that are more costly for the sender and impose no financial costs on subscribers and users, such as person-to-person voice telephony calls, may justify the maintenance of a system giving subscribers or users the possibility to indicate that they do not want to receive such calls. Nevertheless, in order not to decrease existing levels of privacy protection, Member States should be entitled to uphold national systems, only allowing such calls to subscribers and users who have given their prior consent."


      In short, the law is designed to address the imbalance between the ease of pumping out messages, and the time it takes to handle them.

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