[gnso-rds-pdp-wg] ICANN Blog re Session with European DPAs

[jonathan m]

Hi Chuck—I’d like to get a discussion going if that’s okay with you. I’d
like to know whether for the public data set, it is feasible to have the
following solution for the registrant email. It’s based in part on both
technical implications and policy requirements.

1) Registrar required to notify registrants that starting on x date, the
registrant org field will be relied on for purposes of treating the Whois
record as an organizational domain rather than as belonging to a natural
person. Check your record for accuracy because it may have implications for
your privacy if you do not already have or subscribe to proxy or privacy
services. A few reminders go out. Educate registrants they may want to
update to “Domain Admin” instead of having their first and last name for
organizational domains because starting on x date, existing organizational
records will otherwise obfuscate or mask the local part of the registrant
email in public Whois

2) For organizational domains, ICANN will prohibit masking the
organizational domain name in the registrant email address. Registrars are
free to mask the local part of the registrant email address in accordance
with applicable law in the public Whois.

3) for natural persons, registrars will be required to use the same
encrypted hash algorith so there is parity across databases even though
there is no centralized database to manage the encryption. The policy will
be enforced by ICANN and subject to auditing. They can warn registrants of
the associated risks of compromise to give them a chance to take added
precautions and purchase proxy or privacy services.

This would be the minimum requirements for modifying public Whois
registrant email address to avoid damaging the security and stability of
the unique identifiers and DNS. If the downside of doing this is
prohibitive, than ICANN should seek guidance in the April meeting on
whether the public interest in not damaging security and stability
outweighs the privacy interference of having email addresses remain in the
phone books given its not a particularly strong personal indicator to begin
with as privacy and proxy services are available to those that mind as long
as they are notified.

This would result in emails in Whois of natural data subjects being
uniformly hashed so that you can freely see which hash owns what, and Whois
of organizations being freely listed with any local part of such
organizational emails being masked if required by applible law.

I would like to hear a discussion on this from the group this week. Not on
the legality of it under GDPR as the Article 29 working group can weigh in
but first we need to discuss the architectural and policy issues.

Thanks
Jonathan

On Fri, Mar 30, 2018 at 11:27 AM Chuck <consult at cgomes.com> wrote:

> For any of you who have not seen it, the ICANN Blog re the Session with
> European DPAs that occurred yesterday, here is the link:
>
>
>
>
> https://www.icann.org/news/blog/data-protection-privacy-issues-update-discussion-with-article-29-en
>
>
>
> Chuck
> _______________________________________________
> gnso-rds-pdp-wg mailing list
> gnso-rds-pdp-wg at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg

-- 
Jonathan Matkowsky

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