Zone Transfer Policy Review Submission

From:		SearchNZ (Matt Sullivan)
Received:	16 October 2003


With regard to the existing Zone Transfer Policy located at:

  http://dnc.org.nz/content/zone_transfer.pdf

and to the Call for Public Comment located at:

  http://dnc.org.nz/content/zone_transfer_policy_review.pdf

on behalf of SearchNZ we would like to submit the following comments.

Foreword and brief history of SearchNZ

SearchNZ is a 'crawling' (or 'indexing') Web search engine which crawls 
all available web sites within the New Zealand web space. Visitors to 
SearchNZ are able to quickly locate relevant information contained within 
these indexed web pages.  Search query results provide short descriptions 
from each matching page along with links back to the original Web sites. 
Periodically SearchNZ revisits each web site to obtain the latest 
information.

As a companion to its primary web search function SearchNZ has always 
provided a Domain Name Search.  This allows a limited full text fuzzy 
search on the .nz name-space.  Names are listed along with links to 
associated web sites where appropriate.  The SearchNZ Domain Search 
facility provides a valuable research tool to Internet users searching 
for suggestions in choosing a new domain, locating hard to find domains, 
finding variations on domain names and other legitimate uses.

The facility is used by many thousands of New Zealand visitors per 
month and we submit that it is a useful addition to the New Zealand 
Internet.

SearchNZ honors all accepted mainstream standards for indexing control 
such as the "The Robots Exclusion Protocol" and the "The Robots META 
tag". Additionally SearchNZ implements cache control META tags which 
enable web site owners to prevent the display of cached copies of their 
web pages.

More information regarding the "The Robots Exclusion Protocol" and the 
"The Robots META tag" can be found at http://www.robotstxt.org/

Unlike other major search engines SearchNZ has a completely New Zealand 
bias and implements with reasonable tolerance strict checks to ensure 
that the results it provides are New Zealand oriented.

SearchNZ is FREE.  It is provided as a public service to New Zealand Web 
site owners by NZCity to help fulfill its goal of promoting Kiwi Web 
sites to New Zealanders.  Being listed with SearchNZ gives Kiwi Web site 
owners significant free exposure for their products and services.

SearchNZ has been in operation since 1997 and is New Zealand's largest 
domestic search engine.

It is proudly 100% New Zealand owned and operated.

We take our position as a senior, stable and responsible member of the 
New Zealand Internet community seriously.  We feel that any decision 
to remove access to the .nz zone file would significantly detract from 
the facilities that SearchNZ provides and ultimately detrimental to the 
wider New Zealand Internet community.

With regard to the Call for Public Comment it is our view that ...

1. Should any organisation outside the registry company be permitted to
   obtain a copy of the .nz zone file?

   Yes.  The Zone Transfer Policy should define the minimum parameters
   an Applicant must meet in order to demonstrate a legitimate use.
   Any organisation able to demonstrate a legitimate use should be
   permitted access to the .nz zone file.

   In short, it should clearly state the terms under which such access
   may take place, the conditions within which access may be revoked
   (with and without notice) and set well defined boundaries regarding
   the acceptable use and or republication of any derived information.

   All applications should pass through an appropriate review process
   before approval and be subject to periodic review.

   Failing agreement that access to the .nz zone file will continue then
   alternative options should be considered such as regulated and filtered
   versions of the information based on domain holder preferences.
   This may well lead to the creation of separate policy or access
   process as (to our knowledge) this functionality is not available
   in the current SRS implementation.

   SearchNZ would appreciate the opportunity to submit further oral
   and written submissions should any decision to change the status
   quo be forthcoming.

2. If organisations are permitted to obtain a copy of the .nz zone file,
   what criteria should be in place to assess whether their use of the   
   zone file is appropriate?

   At a minimum some brief technical documentation should be required as
   a basis for assessment.  This may not need to be a substantial work
   but merely sufficient to describe the process for which the data is
   required and to what extent (if any) republication of the data will
   occur.

   In particular, if republication of the data is to occur in electronic
   format (via a web server for example) any manipulation of the data
   performed as a result of user interaction should be detailed in terms
   of both the types of manipulation and the expected outputs.  Any such
   manipulations and or outputs must be within policy parameters.

   In many cases common sense will most likely prevail.

3. Should authorised registrars automatically be able to receive a copy  
   of the .nz zone file?

   Not automatically.  Registry data is functionally separate from the .nz
   zone file.  Access to this data is not an operational requirement for a
   registrar.

   However, a suitably complete application within the boundaries of the
   governing Zone Transfer Policy should not necessarily be summarily
   dismissed either.

4. How frequently should copies of the .nz zone file be available to any 
   approved organisations?

   At minimum no more frequently than the current zone push interval and
   possibly with some acceptable delay with respect to any republication
   of new information.

   In any case the minimum frequency and any required republication delay
   should not add additional operational complexity to existing SRS
   operations.  That is to say, it should not be necessary to engineer,
   re-engineer or otherwise create additional processes to facilitate access
   when perfectly good mechanisms already exist and are proven.

   Of course this must remain provisional to the existing policy stipulation
   that any such access must not place undue load on the SRS systems.

5. What information, if any, should any party receiving the .nz zone file 
   be able to make public?

   Only such information as that which is within the public domain and
   with reasonable limitations.

   Such limitations might include:

     - In the case of republished aggregate data:
         a. volume and nature of results

     - In the case of republished aggregate data where user interaction
       is possible:
         a. wild card queries
         b. volume and nature of results
         c. total number per interval and or rate of queries

6. Does the release of the .nz zone file have a negative impact on the
   security of the information held?

   No.  The information contained within the .nz zone file is already
   publicly available in various ways at an individual zone name level.
   The .nz zone file does not contain the type of contact rich information
   that is commonly associated with WHOIS system data but is limited to
   zone names and name server records.

   The primary concern must be the general release of aggregate zone data
   and the potential for subsequent malicious use of such data (e.g. UCE).
   The Zone Transfer Policy should place sufficient limits (such as those
   detailed in 5. above) on any release of aggregate data sufficient to
   dilute its usefulness in this way.

Additional comments

SearchNZ takes an active approach to misuse of its services and has a 
strong Anti SPAM policy.

Any attempt to:

  - include a Web site (or copies) in the engine more than once,
  - submit multiple domain names for the same Web site,
  - submit 'doorway' or 'gateway' pages, 'hidden' links and/or unreadable text,
  - use an automated tool to submit a URL or monitor rankings,
  - submit pages with elements designed to mislead search engine indexers,
  - any other attempt to artificially manipulate the database (note that
    this includes but is not limited to, any suspected attempt to collect
    data for malicious use)

will result in all entries being removed without notice and where appropriate 
further action to be taken as permitted by New Zealand law.

SearchNZ has always maintained an open and willing attitude towards working 
with both the SRS and the DNC to ensure that our use of the NZ zone data is 
within acceptable parameters.  We enforce and monitor restrictions on the 
number of queries made in a given timeframe, the number of results displayed 
and the nature of user interaction against the zone data (e.g. we do not 
allow wild card queries within the Domain Search).

In the history of SearchNZ there has not been a single incident that would 
suggest that our services have been abused for malicious purposes such as 
generating UCE.

We feel that SearchNZ provides a valuable free promotional and research 
oriented tool for New Zealanders and people interested in New Zealand, 
its people, culture, history, politics and the many other great things 
there are to discover about or in New Zealand.

With the above in mind we invite those involved with this review to 
visit SearchNZ and put it to the test.

For general SearchNZ queries:
  http://www.searchnz.co.nz/

For SearchNZ Domain Search queries:
  http://www.searchnz.co.nz/domains/

For general information regarding inclusion in SearchNZ:
  http://www.searchnz.co.nz/addsite/

Information for Webmasters;
  http://www.searchnz.co.nz/webmasters/


Matt Sullivan
SearchNZ