Hello, (I sent the following message as comments on an epdp Report on Temporary Specification for gTLD registration data. But this is more of a comment on Data Protection regulation in general, so copied to the Internet Policy list) In Data Protection terminology, "Personal data" is more of a generic or 'loose' term that applies both to individual and business data. In DNS, Registration Data does not make any distinction between individual registrants and business registrants whose web space is for some form of (e)commerce activity. While there is a need for privacy of personal data of individual registrants, the opposite, need for greater transparency, may be required in the case of data related to any form of commercial, perhaps even Government and non Government web spaces. The rationale is that the online presence of small and large businesses alike are often short of information pertaining to physical location, names of functionaries, officials or the person in-charge. A Phone company does not have listed phone number, an email company does not have a visible email addresses ! This is part of a pattern of multiple players transacting business online from a carefully guarded climate of "do-not-reply" email accounts, phones without a call back number, answering machines, conveniently assisted by BPO intermediaries who keep the consumer at an unapproachable distance. A hotel reservation portal or a small shop online transacts business online without allowing the consumer the ability to reach them for various reasons. Limiting access to Registration data indiscriminately and only for 'legitimate uses' may perpetuate this trend of inaccessibility of business entities, widen the disconnect between business and consumer with the effect that multiple commercial registrants would continue to design their online presence to transact business without due accountability. The section 4.4.2, Lawfulness & Purposes of Processing gTLD Registration Data as written, might have the unintended consequence of perpetuating unhealthy protection for segments that actually require information disclosure and transparency. How the DNS will make such a distinction is another question. Does GDPR make such a distinction? Sivasubramanian M Sivasubramanian M <https://www.facebook.com/sivasubramanian.muthusamy> twitter.com/shivaindia