[Gnso-epdp-team] Recommendation on privacy/proxy data.

Alex Deacon alex at colevalleyconsulting.com
Fri Feb 1 00:56:46 UTC 2019


Our review of ICANN's input on Temp Spec topics that were not covered by
the Initial Report reminded me that we had at one point discussed ensuring
that the current Temp Spec language on how Privacy/Proxy data should be
handled (Appendix A 2.6) should added as a recommendation.   Something
along the lines of -

Recommendation XX

In the case of a domain name registration where a privacy/proxy service
used (e.g. where data associated with a natural person is masked),
Registrar MUST include in the public WHOIS and return in response to any
query full WHOIS data, including the existing privacy/proxy pseudonymized

There are two reasons why this is useful, IMO.

First, given the time and effort needed to properly process "reasonable
disclosure" requests by Registrars it seems useful to avoid a situation
where non-public data is quickly found to be P/P service data.    Avoiding
this situation and simply including P/P data in the the initial response
would make life better for all involved.

Second, there is no need to redact information that is already "redacted"
(by definition) by the P/P service.  Also, given P/P services list the
information of a legal person (in the case of a registrar affiliated
service provider) in the place of the RNH's info it seems further redaction
is unnecessary.

Happy to discuss further on a future call.


*Alex Deacon*
Cole Valley Consulting
alex at colevalleyconsulting.com
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