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Public
Comments on the "Consultation Paper on the Review on Administration
and Assignment of Internet Domain Names and Internet Protocol Addresses
in Hong Kong"
| Reference
No. |
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DN35 |
| Date
of Submission |
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18.7.2000 |
| Submitted
by |
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Inland
Revenue Department |
IRD's Comments on
Consultation Paper on the Review on
Administration and Assignment of Internet Domain Names and
Internet Protocol Addresses in Hong Kong
General Comments
The Role of the Registrar
1. To enable the registrar to perform its functions effectively,
it must have the power to sanction uncooperative applicants and
registrants, including, as a last resort, the power not to renew
or even to cancel the registration of a domain name. Some of these
powers may not be derived from the proposed agreement between the
Government and the registrar.
Fostering Confidence in E-Commerce
2. In the virtual world of electronic commerce, the consumer is
not coming face to face with the merchant. Except where the business
is very well know, the customer does not have much information on
who he is actually dealing with. To give consumers confidence in
the system, we are of the view that the registrar of domain names
should have an important role to play in ascertaining that the business
and/or personal information provided by the applicants are correct,
that any changes to these information are timely reported and recorded
and that the latest information are available for easy retrieval
by members of the public who may wish to do the verification.
Balanced Guiding Principles for Registration
3. The Task Force seems to subscribe to the argument that to facilitate
the development of the Internet and electronic commerce in Hong
Kong, greater flexibility should be allowed in our domain name registration
system (paragraph 13 of the Paper). It has identified as one of
the guiding principles for domain name registration that the application
procedures should be simple to allow efficient processing (paragraph
34 of the Paper). In this connection, we are of the view that while
flexibility and efficiency are important, adequate regulatory control
that gives creditability to the system and improves consumer confidence
is also equally vital. The right balance should be worked out so
that the promotion of flexibility and efficiency would not lead
to too much sacrifice in regulatory control. At the end of the day,
no matter how simple and easy it is for businesses or individuals
to register domain names, electronic commerce cannot really take
off unless the community at large is confident that the playing
field is being properly regulated and that there is a way for them
to seek recourse in case something untoward should happen.
Specific Proposals
Registrar to be a Statutory Body
4. To address the concern in paragraph 1 above, we propose that,
in the long run, it is more desirable for the registrar to be set
up as a statutory body with full legal backing of its work. This
is the only way to ensure that the domain registration functions
can be carried out efficiently and effectively.
Disclosure of Essential Information
5. We would propose that consideration should be given to require
all .hk companies to display vital business information such as
their business names, business addresses and business registration
numbers, etc. prominently on their web pages for ease of identification.
In this regard, we note the Task Force's view that initially only
companies and organizations registered or incorporated in Hong Kong
should be allowed to register domain names ending with .hk. As these
Hong Kong companies/organizations would be required to display their
business registration certificates when trading in the real world,
why should they be allowed not to display the same particulars on
their web pages when trading on the Internet?
6. As an alternative to the proposal in paragraph 5 above, we propose
the domain name registrar to include in the public domain search
database the same vital business information as mentioned above
for .hk companies, viz. the business names, business addresses and
business registration numbers, etc. This will boost the confidence
of the e-customers.
Tightening of Registration Procedures
7. To address the concern in paragraph 3 above, we propose the domain
name registrar to tighten the registration procedures. In particular,
it should always insist on the submission of a copy of the valid
business registration certificate before the registration of a .hk
company can be effected. As for individuals that are proposed to
be registered under a new second-level domain category, the registrar
should also ensure that they are not carrying on businesses, e.g.
by asking the applicant to make a declaration to such effect when
applying for registration.
8. The above proposal is not meant to complicate the registration
procedures nor to impose a restrictive registration policy [paragraph
43 of the Paper]. Instead, the procedures will be more or less the
same as those presently in force except that they will be more strictly
enforced.
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