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

sivasubramanian muthusamy 6.internet at gmail.com
Mon Oct 15 04:22:23 UTC 2018

On Mon, Oct 15, 2018, 6:43 AM Alan Greenberg <alan.greenberg at mcgill.ca>

> 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.

+1.  Such a distinction would be fair. The epdp could also consider
recommending a privacy intensive framework for natural person's data and a
transperncy-centric framework for legal person's data.

> Comments?
> Alan
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