[Accred-Model] Letter from FIRST to ICANN regarding GDPR impact on WHOIS

[John R. Levine]

> It would be of real benefit if FIRST and WP29 came up together with 
> legal basis for accessing whole data repositories in doing threat 
> intelligence, anti-abuse and incident response, ...

A quick look at Article 6, section 1, of the GDPR, finds subsection e) a 
task carried out in the public interest, and f) legitimate interests [of] 
the controller or a third party.  Considering the GAC advice that ICANN 
has received, I think the case for both public interest and legitimate 
interest are overwhelming.

You may disagree, but give it a rest, please.

Regards,
John Levine, johnl at iecc.com, Primary Perpetrator of "The Internet for Dummies",
Please consider the environment before reading this e-mail. https://jl.ly

PS: I do agree that consent is not a strong basis here.