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

Seun Ojedeji seun.ojedeji at gmail.com
Mon Oct 15 10:19:37 UTC 2018

Hello Alan,

I join others to agree that there indeed needs to clear differentiation
between the 2 element, actually am unsure how not differentiating will
better help towards fulfilling GDPR requirements. My hope though is that
the "natural persons" referred will not be to those covered by GDPR alone
but rather to the global registrants.

PS: On a lighter note, what is GDPS as mentioned by Alan? - Lots of Acronym
in ICANN acronymn soup.

On Mon, Oct 15, 2018 at 2:13 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.
> Comments?
> Alan
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*Seun Ojedeji,Federal University Oye-Ekitiweb:      http://www.fuoye.edu.ng
<http://www.fuoye.edu.ng> Mobile: +2348035233535**alt email:
<http://goog_1872880453>seun.ojedeji at fuoye.edu.ng
<seun.ojedeji at fuoye.edu.ng>*

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