[Epdp-dt] General Counsel statement for EPDP Initiation Request (Section E)

[Rubens Kuhl]

I just have to take exception with this part of the statement:

"As outlined in Section 1 of the Advisory Statement to the Temporary Specification for gTLD Registration Data, new data protection laws in Europe impose obligations that would make it impossible for ICANN, registry operators, and registrars to continue to comply with certain ICANN policies and contractual arrangements about how gTLD registration data is processed in the DNS. Without a coordinated approach to addressing these changes, each registry operator and registrar might make their own determination regarding what gTLD registration data should be collected, transferred and published, leading to a fragmentation of the globally distributed WHOIS system and the handling of gTLD registration data. Fragmentation of the WHOIS system would jeopardize the availability of registration data, which is essential to ensuring the security and stability of the Internet, including to mitigate attacks that threaten the stable and secure operation of the Internet."

WHOIS is already a fragmented system. RIR (IP addresses) WHOIS are different from domain WHOIS, and even different among each other; ccTLDs WHOIS are each uniquely different (200+ of them). So even with an homogenous gTLD RDDS, we still have a fragmented system overall.


That said, not expanding that heterogeneity is a worthy goal, even though not affecting security and stability per se.


Rubens


> On 26 Jun 2018, at 11:36, Marika Konings <marika.konings at icann.org> wrote:
> 
> Dear All,
> 
> Please find attached for your information, the General Counsel statement for inclusion in the EPDP Initiation Request. Note this is required content for section E of the EPDP Initiation Request.
> 
> Best regards,
> 
> Marika
> 
> Marika Konings
> Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN)
> Email: marika.konings at icann.org <mailto:marika.konings at icann.org>
> 
> Follow the GNSO via Twitter @ICANN_GNSO
> Find out more about the GNSO by taking our interactive courses <http://learn.icann.org/courses/gnso> and visiting the GNSO Newcomer pages <http://gnso.icann.org/sites/gnso.icann.org/files/gnso/presentations/policy-efforts.htm#newcomers>.
> 
> <General Counsel Statement - Expedited Policy Development Process.docx>_______________________________________________
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