[Comments-proposed-rdap-profile-31aug18] Comments on ICANN org's input to the contracted parties' gTLD RDAP profile proposal

[Gavin Brown]

As CTO of CentralNic I have been involved in both the development of the
RDAP core protocols and the RDAP Pilot Program. CentralNic is a Registry
Services Provider to 75 generic TLDs, and, being based in the EU, is
directly subject to the General Data Protection Regulation.

I agree with almost all of ICANN org’s proposed changes to the RDAP
profile, with one exception, which is #27 (“Require implementation of
searchability in RDAP once an RFC provides such functionality”).

This proposal forces registries which have ICANN’s permission to offer
searchable whois services to offer an RDAP search service. However,
these registries are under no obligation to offer such a service, and in
fact many have withdrawn these services due to the GDPR (ICANN’s
“permission” notwithstanding). It is not appropriate to force these
registries to offer an RDAP search service. Instead, they should merely
be permitted to do so, in the same way they are permitted (but not
obliged) to offer a searchable whois service.

Regards,

-- 
Gavin Brown
Chief Technology Officer
CentralNic Group plc (LSE:CNIC)
Innovative, Reliable and Flexible Registry Services
for ccTLD, gTLD and private domain name registries
https://www.centralnic.com/
+44.7548243029

CentralNic Group plc is a company registered in England and Wales with
company number 8576358. Registered Offices: 35-39 Moorgate, London,
EC2R 6AR.

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