[RDS-WHOIS2-RT] Late markup

[Stephanie Perrin]

Attached is my markup of the document.  Overall, this document is impressive in its scope and research.  Basically, I think many of our recommendations are sensible.  However, the bias towards disclosure of information, the negative attitude towards the GDPR (which my SG applauds as exemplary effort to protect privacy and human rights), and the absence of any explicit recognition of the fact that our WHOIS practices already violated data protection law during the time of the past review are discouraging.  Not to mention the fact that the birth of ICANN coincided with the coming into force of the EU directive, and we have had plenty of advice from the DPAs over the past 19 years telling us how to fix it.   The push to continue doing what we have done since ICANN was born, regardless of changing risks, improvements in data protection, and the existence of many other ways to achieve the security and stability of the Internet, is discouraging.  I realize we had to review the recommendations of the previous Review team.  We live in different times, however, and the evidence of that impacting our review is not there.

Given how many issues I have reservations about, I would like to make a statement, but I am not quite sure where it belongs.  I do not want to resist consensus, but I do want to register some frustration with this process and final result.  I do appreciate that I am a minority view and that you have tolerated my raising my comments and objections throughout the process.

Stephanie Perrin

Chair, NCSG

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