[registration-issues-wg] ICANN Compliance Statement on impact of GDPR on WHOIS Obligations

Carlton Samuels carlton.samuels at gmail.com
Sun Nov 5 18:23:23 UTC 2017


Um, seems we have a problem with the metaphor, Michele.   Here's a hint (*my
emphasis*):

"During this period of uncertainty, and under the conditions noted below,
ICANN Contractual Compliance will defer taking action against any registry
or registrar for noncompliance with contractual obligations related to the
handling of registration data. To be eligible, a contracted party that
intends to deviate from its existing obligations must share its model with
ICANN Contractual Compliance and the Global Domains Division. *To the
extent that the party requests confidential treatment,** ICANN will remove
any identifying information and share only the elements of the model with
the Hamilton law firm for the purpose of legal analysis against the
requirements of the GDPR. The model should reflect a reasonable
accommodation of existing contractual obligations and the GDPR and should
be accompanied by an analysis explaining how the model reconciles the two.
For clarity, Contractual Compliance would not defer enforcement if, for
example, a contracted party submitted a model under which it abandoned
its WHOIS obligations. In addition, a model that satisfies the conditions
noted here might also require compliance with other contractual obligations
or consensus policies, e.g., the Registry Services Evaluation Policy
(RSEP). A model may also require further modifications if it is later
determined not to comply either with the GDPR or any future
community-developed policy.*

Detailed guidance regarding the process and eligibility requirements will
be provided shortly.
​"


-Carlton​








==============================
*Carlton A Samuels*

*Mobile: 876-818-1799Strategy, Planning, Governance, Assessment &
Turnaround*
=============================

On Sun, Nov 5, 2017 at 12:29 PM, Michele Neylon - Blacknight <
michele at blacknight.com> wrote:

> Carlton
>
>
>
> Which part of it do you find unclear?
>
>
>
> Regards
>
>
> Michele
>
>
>
>
>
> --
>
> Mr Michele Neylon
>
> Blacknight Solutions
>
> Hosting, Colocation & Domains
>
> https://www.blacknight.com
>
> https://blacknight.blog /
>
> http://ceo.hosting/
>
> Intl. +353 (0) 59  9183072 <+353%2059%20918%203072>
>
> Direct Dial: +353 (0)59 9183090 <+353%2059%20918%203090>
>
> -------------------------------
>
> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>
> Road,Graiguecullen,Carlow, R93 X265
>
> ,Ireland  Company No.: 370845
>
> *From: *<registration-issues-wg-bounces at atlarge-lists.icann.org> on
> behalf of Carlton Samuels <carlton.samuels at gmail.com>
> *Date: *Sunday 5 November 2017 at 16:19
> *To: *"registration-issues-wg at icann.org" <registration-issues-wg at icann.org>,
> "lac-discuss-en at atlarge-lists.icann.org" <lac-discuss-en at atlarge-lists.
> icann.org>
> *Subject: *[registration-issues-wg] ICANN Compliance Statement on impact
> of GDPR on WHOIS Obligations
>
>
>
> There is its, clear as mud!
>
>
>
> https://www.icann.org/resources/pages/contractual-
> compliance-statement-2017-11-02-en
>
>
>
> -Carlton
>
>
> ==============================
> *Carlton A Samuels*
>
> *Mobile: 876-818-1799 <(876)%20818-1799> Strategy, Planning, Governance,
> Assessment & Turnaround*
> =============================
>
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