[CPWG] Urgent EPDP question

[Alan Greenberg]

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