- comments-proposed-rdap-profile-31aug18@icann.org

[Comments-proposed-rdap-profile-31aug18] Comments-proposed-rdap-profile-31aug18 -- Registrant personal data disclosure
by Riccardo Pecile Oct. 3, 2018

Oct. 3, 2018

Dear Sirs, GDPR only applies to data processing with a nexus to the EEA (European Economic Area) [please find article 3 of "Regulation (EU) 2016/679<https://eur-lex.europa.eu/legal-content/EN/AUTO/?uri=CELEX:02016R0679-20160…>"], so ICANN should limit application of the PUBLISHED ICANN PROPOSED INTERIM MODEL FOR GDPR COMPLIANCE to data processing with an EEA nexus, and specifically prohibit its application to data with no such nexus (such as where neither the contracted party nor the registrant are within the EEA). So we believe that a RDAP Whois service should compel Registrar and Registries to disclose such registrant whois personal data whenever these data would be outside the EEA. Best regards, ------------------------------------------------------------------------------------------------- Riccardo Pecile E-mail: riccardo.pecile(a)convey.it<mailto:riccardo.pecile@convey.it> ------------------------------------------------------------------------------------------------- Convey S.r.l. Via Sagra di San Michele, 27, 10139 Torino (Italy) Tel: +39 011 433 7606 Fax: +39 011 434 1691 E-mail: informazioni(a)convey.it<mailto:informazioni@convey.it> [LogoCONVEYsmall]

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[Comments-proposed-rdap-profile-31aug18] Comments on ICANN org's input to the contracted parties' gTLD RDAP profile proposal
by Gavin Brown Sept. 26, 2018

Sept. 26, 2018

As CTO of CentralNic I have been involved in both the development of the RDAP core protocols and the RDAP Pilot Program. CentralNic is a Registry Services Provider to 75 generic TLDs, and, being based in the EU, is directly subject to the General Data Protection Regulation. I agree with almost all of ICANN org’s proposed changes to the RDAP profile, with one exception, which is #27 (“Require implementation of searchability in RDAP once an RFC provides such functionality”). This proposal forces registries which have ICANN’s permission to offer searchable whois services to offer an RDAP search service. However, these registries are under no obligation to offer such a service, and in fact many have withdrawn these services due to the GDPR (ICANN’s “permission” notwithstanding). It is not appropriate to force these registries to offer an RDAP search service. Instead, they should merely be permitted to do so, in the same way they are permitted (but not obliged) to offer a searchable whois service. Regards, -- Gavin Brown Chief Technology Officer CentralNic Group plc (LSE:CNIC) Innovative, Reliable and Flexible Registry Services for ccTLD, gTLD and private domain name registries https://www.centralnic.com/ +44.7548243029 CentralNic Group plc is a company registered in England and Wales with company number 8576358. Registered Offices: 35-39 Moorgate, London, EC2R 6AR.

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Re: [Comments-proposed-rdap-profile-31aug18] [Ext] Re: [regext] FW: Proposal to remove RDAP from the Thick Whois CL&D Policy (was Proposed Path Forward | Thick Whois CL&D Policy, RDAP and RySG Request for Reconsideration)
by Bernhard Reutner-Fischer Sept. 7, 2018

Sept. 7, 2018

On Tue, 19 Sep 2017 at 18:36, Bernhard Reutner-Fischer <rep.dot.nop(a)gmail.com> wrote: > > On 13 September 2017 at 01:17, Francisco Arias > <francisco.arias(a)icann.org> wrote: > > Thank you for the suggestion, Bernhard. We'll take it into consider if the document is revived, as you said. > > > > -- > > Francisco > > > > On 9/12/17, 2:00 AM, "Bernhard Reutner-Fischer" <rep.dot.nop(a)gmail.com> wrote: > > > The "RDAP Operational Profile for gTLD Registries and Registrars" > > version 1.0 Document erroneously talks about "publicIDs" (as opposed > > to "publicIds" specified in RFC 7483). > > Please fix if the operational profile ever gets revived. > > In general the profile could need a touch-up, IMHO. > > Further notes i took. > > 1.4.10. An RDAP response MUST contain a remarks member with a > description containing the string "This response conforms to the RDAP > Operational Profile for gTLD Registries and Registrars version 1.0". > > Since remarks are only allowed in objects classes and /help is not an > object this requirement should mention "object response" somewhere as > otherwise it would be in violation with the RFC. > > 1.5.20. A domain name RDAP response MUST contain a remarks member with > a title "Whois Inaccuracy Complaint Form", a description containing > the string "URL of the ICANN Whois Inaccuracy Complaint Form: > https://www.icann.org/wicf" and a links member with the > https://www.icann.org/wicf URL. > > Drop the "www." part of the URL to be consistent with 1.5.18 (the > "https://icann.org/epp" URL) The proposed rdap-profile-31aug18 still uses the superlong wicf URL. Please double check the 31aug18 profile against my comments above. thanks,

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