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

John Bambenek jcb at bambenekconsulting.com
Sun Apr 15 13:51:10 UTC 2018


We are again at the first principle. If you think the purpose of ICANN is simply function as a trade association of registrars and registries whose sole mission to enable the transfer of a domain from registrar to registrant, then yes whois/rds in not strictly necessary. 

But that is not the sole purpose of the system or of ICANN. 



--
John Bambenek

> On Apr 15, 2018, at 03:40, Tapani Tarvainen <ncsg at tapani.tarvainen.info> wrote:
> 
>> On Apr 14 16:42, Paul Keating (Paul at law.es) wrote:
>> 
>> To me this is abundantly clear:
>> 
>> constitutes a legitimate interest of the data controller concerned.
> 
> I'm not sure I follow. Any interest of the data controller does not,
> at least not in any obvious way, justify giving personal data they
> are processing to any third parties, let alone the world at large.
> 
>> Insofar as what data is "strictly necessary and proportionate for the
>> purposes of ensuring network
>> and information security,", that certainly includes the following:
>> 
>> Name (or other means of permitting attribution and identification)
>> Email (same)
>> IP address
>> Creation date
> 
> Without going now into that beyong noting that even those are debatable,
> what definitely isn't strictly necessary is publishing all that to the
> entire world.
> 
> -- 
> Tapani Tarvainen
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