[registration-issues-wg] [CPWG] Urgent EPDP question

Nadira Alaraj nadira.araj at gmail.com
Mon Oct 15 03:42:26 UTC 2018

In agreement of contractual parties of having 2 systems,  one to protect
the "natural person" privacy information for every one globally and not
only those from Europe.
The second is for the "legal persons" and because they're under licence
agreements in the legal system of their respective countries.  Hence moving
to a two registered system has to have a limited and derminate timeframe to
move towards the dual registrant system. I don't think their concerns about
changing the system, but it seems it goes beyond that.

If there are concerns about the micro commercial business for individual
who function without any registration in their countries, it would be their
individual problem in how to be accountable to their countries requirements.


On Mon, Oct 15, 2018, 05:01 Holly Raiche <h.raiche at internode.on.net> wrote:

> Folks
> An  argument against differentiation is that the contracted parties want
> to be able, as much as possible, to implement one system for managing
> information rather than having to differentiate between the license of a
> name being a natural person and the licensee of a name being a corporate
> person.
> Another is says that there are circumstances where information about legal
> entities may amount to personal information - for example, when a small
> business (usually a legal person) has used the actual name of the person as
> the business name, or where, in the case of a legal person, the contact
> details provided are for  a named individual - thus GDPR protections should
> apply uniformly.
> My personal view is that, from the perspective of users, the protections
> of GDPR really need only apply to natural persons.
> That means that companies will need to be careful not to provide personal
> contact information for the RAA/Registry agreements.  And from an end user
> point of view, the management of systems to differentiate legal from
> natural persons is not our concern.
> Holly
> > On Oct 15, 2018, at 12:12 PM, Alan Greenberg <alan.greenberg at mcgill.ca>
> wrote:
> >
> > Here is a question that we need an answer on no later than Tuesday
> morning.
> >
> > GDPR requires the information related to Natural Persons be protected
> (for those resident in Europe) be protected. GDPR does not apply to Legal
> Persons (ie companies).
> >
> > ICANN's Temporary Spec allows contracted parties to treat all registrant
> alike and subject to GDPR.
> >
> > The EPDP Charter includes questions about whether contracted parties may
> or must treat Legal Persons differently from Natural Persons.
> >
> > The GAC, BC and IPC have made strong statements about the need to
> restrict GDPS to Natural Persons. The contracted parties are pushing back -
> strongly. The words vary, but in essence what they are saying ranges from
> there should be no constraint on them to yes, they may differentiate but
> with an unspecified time-frame.  (As you may note if you looked at the
> RDS-WHOIS2 report, registrars under the 2013 RAA must do some validation of
> contact information for new an transfered domains, but none to simple
> renewal. so there are currently 140,000,000 domains without verified
> information (5 years after the 2013 RAA came into force) and there is no
> requirement to ever validate their information - so unspecified time frames
> can last a LONG time.)
> >
> > I personally feel that it is essential that we should differentiate
> between legal persons and natural persons, just as GDPR and other privacy
> legislation does.
> >
> > Comments?
> >
> > Alan
> >
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