[gnso-rds-pdp-wg] Krebs On Security article RE whois and GDRP

Ayden Férdeline icann at ferdeline.com
Fri Feb 16 19:01:42 UTC 2018


Such a distinction sounds complex for a registrar to make, and even more burdensome for a registrar to implement. Who could afford to do this? I would also worry that such costs would be passed on to domain name registrants.

— Ayden

-------- Original Message --------
On 16 February 2018 7:52 PM, John Horton via gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org> wrote:

> I think quite a bit in this WG and certainly in the prior privacy/proxy PDP, and absolutely what we're seeing with GoDaddy. To make sure I'm being clear about what I mean, GoDaddy isn't only redacting Whois information (via Port 43) where it's an EU natural citizen or natural resident. The information is being redacted for....everyone. All registrants. There's simply no justification for that.
>
> I predict you'd see (I'm not speaking for anyone here, just me) a real willingness on the security and compliance community's part to compromise and support a system where, IF a registrant is an EU natural person (yes, I know we need to define it accurately -- citizen, resident, we can get granular later) then...hey, let's set up a system in involving redaction of some fields, access to those fields in legitimate cases, etc. I want to support registrars' compliance with the GDPR. But we're seeing the registrar community say: We want to apply this globally. To all domain name registrations. Doesn't matter if the registrant is the intended beneficiary of the new law, or in scope, or not. We're going to just change global policy.
>
> I think that viewpoint has been pretty repeatedly represented in this working group, but I'd love to hear from registrars that would support a more targeted solution where only the intended beneficiaries of the GDPR (that is, in-scope registrants) are covered under the policy.
>
> John Horton
> President and CEO, LegitScript
>
> Follow LegitScript: [LinkedIn](http://www.linkedin.com/company/legitscript-com)  |  [Facebook](https://www.facebook.com/LegitScript)  |  [Twitter](https://twitter.com/legitscript)  |  [Blog](http://blog.legitscript.com/)  |  [Newsletter](http://go.legitscript.com/Subscription-Management.html)
>
> On Fri, Feb 16, 2018 at 10:44 AM, benny at nordreg.se <benny at nordreg.se> wrote:
>
>> Please refer to where registrars have been unwilling to explore this option?
>>
>> --
>> Med vänliga hälsningar / Kind Regards / Med vennlig hilsen
>>
>> Benny Samuelsen
>> Registry Manager - Domainexpert
>>
>> Nordreg AB - ICANN accredited registrar
>> IANA-ID: 638
>> Phone: [+46.42197000](tel:%2B46.42197000)
>> Direct: [+47.32260201](tel:%2B47.32260201)
>> Mobile: [+47.40410200](tel:%2B47.40410200)
>>
>>> On 16 Feb 2018, at 19:38, John Horton via gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org> wrote:
>>>
>>> Just imagine how much of all of this could be avoided if registrars were willing to agree to a commercial/individual distinction.
>>>
>>> John Horton
>>> President and CEO, LegitScript
>>>
>>>
>>> Follow LegitScript: LinkedIn  |  Facebook  |  Twitter  |  Blog  |  Newsletter
>>>
>>>
>>>
>>> On Fri, Feb 16, 2018 at 10:33 AM, John Bambenek via gnso-rds-pdp-wg <gnso-rds-pdp-wg at icann.org> wrote:
>>> GDPR taken to its logical extreme very well could require us to abandon IP reputation and to emptying our firewalls. I mean, no consumer authorized me to process their IP just by attacking me, right?
>>>
>>> Privacy absolutism is not the answer unless you basically want to mandate the internet backbone be converted to tor.
>>>
>>> --
>>> John Bambenek
>>>
>>> On Feb 16, 2018, at 06:09, Michele Neylon - Blacknight <michele at blacknight.com> wrote:
>>>
>>>> It’s an interesting read, but it has several flaws.
>>>>
>>>> It refers to registrars solely and ignores registries.
>>>>
>>>> It also makes it sound like issues around whois are “new”, which we all know isn’t true.
>>>>
>>>> The comments about IP addresses make it sound like it’s a theoretical concern, yet there is case law eg:
>>>>
>>>> https://www.irishtimes.com/business/technology/european-court-of-justice-rules-ip-addresses-are-personal-data-1.2835704
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>>
>>>> --
>>>>
>>>> Mr Michele Neylon
>>>>
>>>> Blacknight Solutions
>>>>
>>>> Hosting, Colocation & Domains
>>>>
>>>> https://www.blacknight.com/
>>>>
>>>> http://blacknight.blog/
>>>>
>>>> Intl. [+353 (0) 59 9183072](tel:%2B353%20%280%29%2059%20%209183072)
>>>>
>>>> Direct Dial: [+353 (0)59 9183090](tel:%2B353%20%280%2959%209183090)
>>>>
>>>> Personal blog: https://michele.blog/
>>>>
>>>> Some thoughts: https://ceo.hosting/
>>>>
>>>> -------------------------------
>>>>
>>>> Blacknight Internet Solutions Ltd, Unit 12A,Barrowside Business Park,Sleaty
>>>>
>>>> Road,Graiguecullen,Carlow,R93 X265,Ireland  Company No.: 370845
>>>>
>>>> From: gnso-rds-pdp-wg <gnso-rds-pdp-wg-bounces at icann.org> on behalf of Dotzero <dotzero at gmail.com>
>>>> Date: Friday 16 February 2018 at 00:07
>>>> To: RDS PDP WG <gnso-rds-pdp-wg at icann.org>
>>>> Subject: [gnso-rds-pdp-wg] Krebs On Security article RE whois and GDRP
>>>>
>>>>
>>>>
>>>>
>>>> https://krebsonsecurity.com/2018/02/new-eu-privacy-law-may-weaken-security/
>>>>
>>>> Michael Hammer
>>>>
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