[gnso-rds-pdp-wg] Facebook loses Belgian court case over consent and tracking

[Rubens Kuhl]

> Em 21 de fev de 2018, à(s) 01:14:000, Steve Crocker <steve at shinkuro.com> escreveu:
> 
> Stephanie,
> 
> Some folks are saying address records, names of name servers and perhaps other records might have personally identifying information.  I would not argue these records do not ever have personally identifying information, I do argue it’s immaterial.  It’s essential these records are universally accessible and because this is well known, anyone who chooses to publish these records has implicitly granted permission for others to access this information.  Policy people, legislators, regulators cannot impose a new requirement on the design and operation of the DNS as if the possibility of mediating access were an available option.


Steve,

Just a small repair: name servers are only public if the domain statuses do not contain clientHold or serverHold, and if the domain actually has name servers. So the question is whether RDS should publish future servers (WHOWILLBE ?); and even when the domain is currently published in the TLD zone, the information on RDS is redundant and subject to being outdated (current RA allows a delay of 60 minutes). On IP addresses, there might be difference between in-bailwick addresses and those that are not, if allowed by that TLD.

So considering computer systems design principle of not duplicating data unless there is a compelling reason to do it and the data minimization principle, I think it's just easier to get name servers and their IP addresses out of RDS... we save time discussing those data fields and considering their implications.
They will still be public information in the situations they are public, and any data privacy impact should make clear that there is no expectation of privacy to it. We would just list them at their native habitat, the DNS system.


Rubens




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