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

[Chuck]

Jonathan,

 

As I said in the message I sent a few minutes ago to you and Rubens, I do not think that this is a good time to initiate the suggestion you describe below, but I do suggest that bring up your ideas as applicable in the future when we deliberate on data elements and gated access.

 

Chuck

 

From: jonathan m <jonathan.matkowsky at riskiq.net> 
Sent: Friday, March 30, 2018 9:08 AM
To: Chuck <consult at cgomes.com>
Cc: gnso-rds-pdp-wg at icann.org
Subject: Re: [gnso-rds-pdp-wg] ICANN Blog re Session with European DPAs

 

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 <mailto: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 <mailto:gnso-rds-pdp-wg at icann.org> 
https://mm.icann.org/mailman/listinfo/gnso-rds-pdp-wg

-- 

Jonathan Matkowsky


*******************************************************************
This message was sent from RiskIQ, and is intended only for the designated recipient(s). It may contain confidential or proprietary information and may be subject to confidentiality protections. If you are not a designated recipient, you may not review, copy or distribute this message. If you receive this in error, please notify the sender by reply e-mail and delete this message. Thank you.

*******************************************************************

-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/gnso-rds-pdp-wg/attachments/20180331/71243c77/attachment-0001.html>