[gnso-rds-pdp-wg] Equifax hack worse than previously thought: Biz kissed goodbye to card expiry dates, tax IDs etc

[Rubens Kuhl]

> On 13 Feb 2018, at 20:32, John Horton <john.horton at legitscript.com> wrote:
> 
> Thanks, Rubens -- I don't agree with that interpretation. (I think you mean the Q&A memo Section 2, right?) See memo here <https://www.icann.org/en/system/files/files/gdpr-memorandum-part2-18dec17-en.pdf>. Let me know if you meant the first or a different one.


It's exactly that memo.
Since you don't agree, does that mean that your organisation is willing to pay every GDPR fine contracted parties get from following your interpretation ? Because if you are unwilling to do that, then your belief in that interpretation is not rock solid.

What I can tell you is that this risk has been flagged by that paper, by the eco model and by internal analysis of some registries, all independently of each other; which means you will likely see a good number of contracted parties following exactly the path I outlined in order to mitigate this risk.

If you see things differently, get Europeans DPAs to put that in writing, and we are all good to go.



Rubens



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