[gnso-rds-pdp-wg] Using the GDPR as a basis for RDS Policy is backwards

[John Horton]

Hmm, well, perhaps it's because I work for a company that processes quite a
bit of data with a combination of algorithms and some human review, but I
feel pretty confident that there are ways to simplify that with magic
algorithms and forms.

John Horton
President and CEO, LegitScript


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On Wed, Feb 14, 2018 at 2:35 PM, Rubens Kuhl <rubensk at nic.br> wrote:

>
>
> On 14 Feb 2018, at 19:37, John Horton via gnso-rds-pdp-wg <
> gnso-rds-pdp-wg at icann.org> wrote:
>
> Michele,
>
> One leading (US-based) registrar informed me that even though they could
> be more granular if they wished to, they wanted to just extend the
> identical (i.e., GDPR-level) protections to all registrants globally simply
> due to "cost-benefit analysis" -- that it was more convenient for them and
> less work. I personally do not consider that a valid justification,
> standing alone. I do not wish any registrar to incur unreasonable costs,
> but a registrar's profit margin goals should not drive policy.
>
>
>
> I believe that was most in the context of legal/natural persons. While
> GDPR clearly doesn't apply to a legal person name/location/phone/role-account-email,
> manually reviewing data to assert that goes beyond reasonable in
> cost-benefit for a system that is fully automated today. Answering
> questions like the ones below require such manual review:
>
> - Is the registrant name of a legal person ?
> - Is the registrant name of a legal person when an user informed
> registration by a legal person but incorrectly put his name as registrant ?
> - Is the location of the business the residence of the owner ?
> - Is the e-mail address a role-account e-mail like legal at company or a
> personally identifiable e-mail like johnhorton at legitscript ?
> - Is the phone number the main line of the company, an unpublished
> extension number or a mobile number ?
>
>
> Is manually reviewing all registration a reasonable cost in your opinion ?
>
>
>
> Rubens
>
>
>
>
>
>
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