Hi Michele, See below. At 01/08/2018 12:33 PM, Michele Neylon - Blacknight wrote:
Alan
1 - good 2 - good 3 - I don't understand what that means
If we were concerned only with Registrants, privacy is a really good thing for them and we would want more of it. From a pure user point of view, if GDPR makes it harder for those knowledgeable ones to access WHOIS and makes it hard for the others listed in 4 to get quick and effective access, so privacy is bad. In our minds, we represent both, and we have to decide where to draw the line. Based on a principle we established a decade ago, we go with the numbers and take a user perspective. (And to be clear, there is a small contingent of our community that does not agree!)
4 - Why are you combining law enforcement and private parties? Law enforcement can always get access to data when they follow due process.
Law enforcement is a heavy user of WHOIS at the moment (or perhaps better said, pre-GDPR). Yes, they will be able to get access through due process, but that is slow and often will not be done, so access will be less. Perhaps a lot so. And there may be disclosure requirements that might be considered problematic (telling registrant that their information has been requested). Wearing my hat as Chair of the WHOIS2-RDS Review, this is one of the issues that we are investigating and hope to report on in our Draft Report out in a few weeks. Alan
Regards
Michele
-- Mr Michele Neylon Blacknight Solutions Hosting, Colocation & Domains https://www.blacknight.com/ https://blacknight.blog/ Intl. +353 (0) 59 9183072 Direct Dial: +353 (0)59 9183090 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
On 01/08/2018, 17:27, "registration-issues-wg on behalf of Alan Greenberg" <registration-issues-wg-bounces@atlarge-lists.icann.org on behalf of alan.greenberg@mcgill.ca> wrote:
Yesterday, the EPDP Members were asked to present a 1-3 minute summary of their groups position in regard to the EPDP. The following is the statement agreed to by me, Hadia, Holly and Seun.
1. The ALAC believes that the EPDP MUST succeed and will be working toward that end.
2. We have a support structure that we are organizing to ensure that what we present here is understood by our community and has their input and support.
3. The ALAC believes that individual registrants are users and we have regularly worked on their behalf (as in the PDP that we initiated to protect registrant rights when their domains expire), if registrant needs differ from those of the 4 billion Internet users who are not registrants, those latter needs take precedence. We believe that GDPR and this EPDP are such a situation.
4. Although some Internet users consult WHOIS and will not be able to do so in some cases going forward, our main concern is access for those third parties who work to ensure that the Internet is a safe and secure place for users and that means that law enforcement, cybersecurity researchers, those combatting fraud in domain names, and others who help protect users from phishing, malware, spam, fraud, DDoS attacks and such can work with minimal reduction in access to WHOIS data. All within the constraints of GDPR of course.
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