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

[Bill Silverstein]

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
>>
>> _______________________________________________
>> CPWG mailing list
>> CPWG at icann.org
>> https://mm.icann.org/mailman/listinfo/cpwg
>> _______________________________________________
>> registration-issues-wg mailing list
>> registration-issues-wg at atlarge-lists.icann.org
>> https://mm.icann.org/mailman/listinfo/registration-issues-wg
>>
> _______________________________________________
> CPWG mailing list
> CPWG at icann.org
> https://mm.icann.org/mailman/listinfo/cpwg
> _______________________________________________
> registration-issues-wg mailing list
> registration-issues-wg at atlarge-lists.icann.org
> https://mm.icann.org/mailman/listinfo/registration-issues-wg
>