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

Margie Milam margiemilam at fb.com
Fri Feb 1 17:00:52 UTC 2019

I agree with  Alex’s proposal below.

All the best,

From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Alex Deacon <alex at colevalleyconsulting.com>
Date: Thursday, January 31, 2019 at 4:57 PM
To: EPDP <gnso-epdp-team at icann.org>
Subject: [Gnso-epdp-team] Recommendation on privacy/proxy data.


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 email.

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<mailto:alex at colevalleyconsulting.com>

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