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

Olivier MJ Crépin-Leblond ocl at gih.com
Mon Oct 15 07:40:30 UTC 2018


contact at company.com
Tel: switchboard: xxxxxxxxxx
Address of company: xxxxxxxxx

What kind of a company is company that does not want to be contactable?
Seriously?
Kindest regards,

Olivier

On 15/10/2018 10:28, Bill Silverstein wrote:
> The problem with this is a corporate entity would have the name,
> telephone, and address of the contact individual in the whois information.
> That  proposal will include that individual under the GDPRs of a contact.
>
>
> On Sun, October 14, 2018 9:22 pm, sivasubramanian muthusamy wrote:
>> On Mon, Oct 15, 2018, 6:43 AM 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.
>>>
>> +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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>
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