[gnso-rds-pdp-wg] CIRCL - Luxembourg CERT Statement on WHOIS

[John Bambenek]

Answers inline. 

--
John Bambenek

> On Apr 14, 2018, at 10:28, Rubens Kuhl <rubensk at nic.br> wrote:
> 
> 
> 
>> On 14 Apr 2018, at 11:42, Paul Keating <paul at law.es> wrote:
>> 
>> To me this is abundantly clear:
>> 
>> constitutes a legitimate interest of the data controller concerned.
>> 
>> 
>> The issue is then one of ensuring that access is limited to those falling
>> within the description in the Recital AND ensuring that the users are
>> informed and retain such rights relative to the data as the GDPR would
>> otherwise require.
>> 
>> Insofar as what data is "strictly necessary and proportionate for the
>> purposes of ensuring network
>> and information security,幹, that certainly includes the following:
>> 
>> Name (or other means of permitting attribution and identification)
> 
>> Email (same)
> 
> Other means of attribution and identification is key here: only an unique transformation of that info is required, not the actual info

Wrong. 
> 
>> IP address
> 
> If you are mentioning the IP address use to create the domain, I don't see that in any RDS system today. I suggest that at first we try using what is already published, and only bringing new data elements later on.

Well A records but that is not in scope here. 
> 
>> Creation date (statistics show that domains are weaponized very shortly
>> after registraiton.  However, once the bad actors are aware of this they
>> will pivot to using stale domains they have long ago registered)
> 
> I believe that was supposed to still be part of public WHOIS.
> 

Ok

>> History (this is important so as to track domain abuse both in terms of
>> highjacking and to verify ownership t rails relative to attribution and
>> identification)
> 
> I also don't see that in any RDS system today as well. But anyways, name server history - which is public - is probably good to do the same thing without PII.

Which is why industry has created systems to do this. Very systems that people on this list and loudly and consistently have stated need to be bankrupted. 

> 
> 
> Rubens
> 
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