contact@company.com Tel: switchboard: xxxxxxxxxx Address of company: xxxxxxxxx What kind of a company is company that does not want to be contactable? Seriously? Kindest regards, Olivier On 15/10/2018 10:28, Bill Silverstein wrote:
The problem with this is a corporate entity would have the name, telephone, and address of the contact individual in the whois information. That proposal will include that individual under the GDPRs of a contact.
On Sun, October 14, 2018 9:22 pm, sivasubramanian muthusamy wrote:
On Mon, Oct 15, 2018, 6:43 AM Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
Here is a question that we need an answer on no later than Tuesday morning.
GDPR requires the information related to Natural Persons be protected (for those resident in Europe) be protected. GDPR does not apply to Legal Persons (ie companies).
ICANN's Temporary Spec allows contracted parties to treat all registrant alike and subject to GDPR.
The EPDP Charter includes questions about whether contracted parties may or must treat Legal Persons differently from Natural Persons.
The GAC, BC and IPC have made strong statements about the need to restrict GDPS to Natural Persons. The contracted parties are pushing back - strongly. The words vary, but in essence what they are saying ranges from there should be no constraint on them to yes, they may differentiate but with an unspecified time-frame. (As you may note if you looked at the RDS-WHOIS2 report, registrars under the 2013 RAA must do some validation of contact information for new an transfered domains, but none to simple renewal. so there are currently 140,000,000 domains without verified information (5 years after the 2013 RAA came into force) and there is no requirement to ever validate their information - so unspecified time frames can last a LONG time.)
I personally feel that it is essential that we should differentiate between legal persons and natural persons, just as GDPR and other privacy legislation does.
+1. Such a distinction would be fair. The epdp could also consider recommending a privacy intensive framework for natural person's data and a transperncy-centric framework for legal person's data.
Comments?
Alan
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