[Gnso-epdp-team] Additional Information -- Topics related to Consent

[James M. Bladel]

This may come as a surprise, but we note that some segment of our customers are also asking for a means to “opt-in” to WHOIS publication, if their contact data is redacted by default.

Of course, we’d need to find a way to do this that is both legally defensible and technically/commercially workable.  The devil is in the details….

J.

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James Bladel
GoDaddy


From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Benedict Addis <bee at theale.co.uk>
Date: Monday, December 10, 2018 at 10:12
To: "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Additional Information -- Topics related to Consent

The SSAC workparty has discussed registrant consent and we support Margie’s proposal below.

Best,
Benedict.


On 8 Dec 2018, at 00:52, Margie Milam <margiemilam at fb.com<mailto:margiemilam at fb.com>> wrote:

Hi  –
Per our discussion, here is information to frame our discussion related to a few of the additional topics we raised:


  1.  Registrant Consent to Publication -

Scope:  The EPDP Charter (Part 1(f)) relates to publication of data.

Issue:  Whether registrars should give the registrant the option to opt in to having their WHOIS Contact Data be published rather than be redacted.   This is an issue that would be available to both natural persons and legal persons.

Temporary Specification: The Temporary Specification 7.2.1/ Appendix C – Section 2.3 contains this requirement:

As soon as commercially reasonable, Registrar MUST provide the opportunity for the Registered Name Holder to provide its Consent to publish the additional contact information outlined in Section 2.3 of Appendix A for the Registered Name Holder.

Proposed Policy:  Confirm this requirement

Rationale:   Registrants such as corporations conducting online business may wish to display their information to ensure that their customers can confirm the authenticity of their website and prevent phishing and other impersonations.   Domainers may wish to be easily contactable in order to solicit interest in secondary sales of their domain names.   Enabling the consent feature is consistent with the accountability principles laid out in GDPR.
EPDP Initial Report:  Silent on the issue of consent

GDPR Legal Basis – Article 7 of GDPR


  1.  Consent by the Registrant to Publish and/or Disclose for technical contact -

Scope:  The EPDP Charter (Part 1(f)) relates to publication of data.

Issue:  Whether registrars should seek consent from those listed as additional contacts (admin/tech) to having their information as reflected in the Contact data be published rather than be redacted.   This is an issue that would be available to both natural persons and legal persons.

Temporary Specification: The Temporary Specification 7.2.1/ Appendix C – Section 2.3 contains this requirement:
Registrar MAY provide the opportunity for the Admin/Tech and/or other contacts to provide Consent to publish additional contact information outlined in Section 2.4 of Appendix A.

EPDP Initial Report:  Silent on the issue of consent

GDPR Legal Basis – Article 7 of GDPR

Proposed Policy:  Confirm this requirement

Rationale:   To avoid inadvertently publishing personal data, this option should be available to registrars.

Have a great weekend!

All the best,

Margie


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