Why Nominet Has Got It Wrong About The Royal Mail And Bad Actors

With far less fanfare than you might imagine, the UK domain name space is going to be revolutionised this week. From 8am on Tuesday the 10th of June, Nominet will allow you to register shorter .uk domain names for the very first time.

It will still be possible to register and use .co.uk domain names, along with .org.uk, .me.uk and all the other domains ending in .uk that currently exist, but as well as georgemarshall.co.uk, for example, it will now be possible to register georgemarshall.uk.

The new .uk domain names come with their own set of rules and regulations, but none so strange as the following:

“We have decided not to allow the use of a PO Box as an address for a registrant or as an address for service, as we were informed that this could create a significant loophole for ‘bad actors’ to exploit.”

Bad actors? Don’t worry. Nominet aren’t having a dig at the Joey Tribbianis of this world. Or at least, I don’t think they are. It’s more likely they mean bad actors in the legal sense: criminal types.

You should be worried, however, if you run a legitimate business that uses a PO Box and that trades online because this will affect you.

What I would like to know is what this significant loophole is, who informed Nominet of this loophole,  and on what grounds was it accepted as valid? Because from where I’m standing, there is no loophole that PO Boxes afford bad actors – and if there is one, it applies equally to all addresses.

PO Boxes are provided by Royal Mail and when you apply for one it is made very clear that Royal Mail will:

“disclose your full street address to enquirers. Do not use this service if you do not want your address to be revealed.”

That’s not what bad actors want to hear.

You also need to supply Royal Mail with two of the following when applying for a PO Box (documentation must not be more than three months old):

a bank or building society statement
• a telephone bill (but not mobile)
• a utility bill
• a council tax bill
• a driving licence (paper counterpart)
• a mortgage statement
• a tenancy agreement

Again, not really music to the ears of bad actors.

These checks by Royal Mail go well beyond any that Nominet asks its Registrars to make when allowing a customer to register a domain name – and yet Nominet are allowing the use of a Registrar’s address as an address for service for customers. Bad actors take note!

What’s more, Nominet are apparently allowing .uk Registrants to use private mail forward services that provide a street address. Such services are under no obligation to disclose addresses to enquirers and often go to extraordinary lengths to hide the identity of their customers. Here’s some of the attractions of working with The Post House for example:

“You can change your forwarding address instantly, as often as you wish, via your secure control panel and, to further protect your privacy, The Post House does not retain a record of any previously registered addresses.”

“The Post House does not require any proof of identity and will never ask for your real name. You are only ever identified on our system by your unique mailbox address… and payments are made via Paypal to maintain your anonymity.”

You could drive a double decker bus through loopholes like that – and yet Nominet have chosen to focus solely on PO Boxes.

And it’s not as if “bad actors” don’t use street addresses anyway. Fly-by-night operation are renowned for taking an office on a short-term lease, fleecing the public, and then disappearing with all the money before anyone knows they have shut up shop. That presumably makes street addresses a significant loophole. Will Nominet take steps to outlaw their use too?

Even stranger, if PO Boxes are such a concern when it comes to bad actors, why are Registrants allowed to use PO Boxes when registering .co.uk domain names? In fact, I’d be really interested to know what level of complaints Nominet has received since its formation in 1996 with regards to Registrants using PO Boxes compared to those using street addresses.

I’d also be really interested to hear what the Royal Mail think about this, but the real losers here are the large number of people who are entitled to work from home – as long as they don’t use their residential address as a business address. This is a common condition placed on those renting residential property. For them, a PO Box can be a lifeline that allows them to trade without jeopardising their tenancy while knowing that their mail is being handled by one of the most trusted companies in the UK today. Nominet hasn’t given them a second thought when rushing to close this “significant loophole”.

Banning the use of PO Boxes is nothing more than unnecessary red tape – and that’s the last thing British businesses need at this moment in time. In any case, we already have something in place to deal with bad actors no matter what address they use. It’s called the law of the land. 

Time to think again, Nominet.

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