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

[Volker Greimann]

DPAs are law enforcement and will enforce the law of the land. They do 
not have the option to pick and choose after May 25.

Maybe it is time for you and your colleagues to start looking at other 
sources of information to ensure you can continue operation efficiently 
once your currently chosen method becomes illegal. Remember, you are a 
data processor too and what you do with that data could very well paint 
a target on your backs that DPS may have to deal with.

Best,

Volker



Am 15.02.2018 um 02:36 schrieb allison nixon:
> Hi everyone,
>
> I have already begun to hear unrest from my colleagues who work in 
> infosec and network operations about the degradation of WHOIS, as 
> registrars have already begun to act on their own, stripping 
> everything and blocking bulk queriers on domains frequently used for 
> attacks. Every day of additional uncertainty equals an additional day 
> of victimization.
>
> Why has no one approached the DPAs with the evidence of security 
> purposes for WHOIS? How much network degradation will we tolerate 
> before someone bothers to give them a little hint? How many more 
> judgments from the DPAs are we going to read that display clear 
> ignorance of all legitimate cybersecurity purposes? Did no one see 
> this coming?
>
> Since we are talking about cost benefit analysis, here is a quick one 
> I just did that I would like to share with the group. I did a quick 
> look for the value of the domain registration industry as a whole. 
> Seems to be ~$4 billion. The losses incurred by the WanaCry malware 
> are estimated to be at ~$8 billion. A single security incident 
> destroying value equal to double your entire industry.
>
> In May 2017, the FBI stated that over three years the "business email 
> compromise" scams have topped ~$5 billion in losses, which would be 
> slightly more than one domain-industry unit of value, and WHOIS is 
> crucial to fighting it.
>
> source: 
> https://www.reuters.com/article/us-cyber-lloyds-report/global-cyber-attack-could-spur-53-billion-in-losses-lloyds-of-london-idUSKBN1A20AB
> source: 
> https://cira.ca/factbook/domain-industry-data-and-canadian-Internet-trends/domain-name-industry
> source: 
> https://www.csoonline.com/article/3195010/security/bec-attacks-have-hit-thousands-top-5-billion-in-losses-globally.html
>
> Remember, the whole point of GDPR is to force companies to act with 
> more social responsibility.
>
> On Wed, Feb 14, 2018 at 6:08 PM, Rubens Kuhl <rubensk at nic.br 
> <mailto:rubensk at nic.br>> wrote:
>
>
>
>>     On 14 Feb 2018, at 20:49, John Horton
>>     <john.horton at legitscript.com
>>     <mailto:john.horton at legitscript.com>> wrote:
>>
>>     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.
>
>
>     Magic algorithms are fine in pattern detection because there is
>     always a human review at some point or the cost of error is low,
>     like in raising an abuse case that contains wording like
>     supposedly", "allegedly" etc. In this case, every false negative
>     comes with a tremendous liability.
>
>     Also, if machine-learning technology and deep pockets for lawsuits
>     become a requirement for being a registrar, you can count on the
>     number of registrars dropping to single digits.
>
>
>
>     Rubens
>
>
>
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>
>
>
> -- 
> _________________________________
> Note to self: Pillage BEFORE burning.
>
>
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