[Gnso-epdp-team] On the proposed guidance

Thomas Rickert epdp at gdpr.ninja
Thu Apr 22 12:00:55 UTC 2021


Let me go on the record that I also like the idea. 

I addition to the points mentioned by others, making it a one-stop-shop for all data would make it more user friendly, add safeguards against undesirable correlation of data and allows for kicking-out bad actors even at that level.

Best,
Thomas

> Am 20.04.2021 um 23:49 schrieb Volker Greimann via Gnso-epdp-team <gnso-epdp-team at icann.org>:
> 
> Hi Milton,
> 
> essentially, yes, although it would be non-personal data.
> 
> And it takes care of a huge chunk of DNS abuse (the abuse originating from the RDS harvesters, that is).
> -- 
> Volker A. Greimann
> General Counsel and Policy Manager
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> 
> On Tue, Apr 20, 2021 at 8:47 PM Mueller, Milton L via Gnso-epdp-team <gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>> wrote:
> > Obviously I can’t speak for Volker, but I want to try and respond with why I find Volker’s
> 
> > proposal intriguing.
> 
>  
> 
> I too am intrigued by this suggestion. Volker as I understand it proposed that instead of publishing the data as we used to do with “ye olde Whois” (love that term), we would make the data of those who flag themselves as legal persons available automatically to any registered SSAD user who requests it. Other requests would be available based on the review for legitimate purpose as originally envisioned.
> 
>  
> 
> As Marc suggests, going through SSAD eliminates a lot of abusers/bad actors or at least gives us some recourse against them, but still gives all the legitimate users easy access to data that does not need to be private. I would hope this option would be acceptable to the stakeholders who are arguing for a legal/natural distinction.
> 
>  
> 
> Dr. Milton L Mueller
> 
> Georgia Institute of Technology
> 
> School of Public Policy
> 
>  
> 
>  
> 
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