Sorry to be the continuous wet blanket here, but again I need to call a halt to overreach and assumptions.
The ORG process discussions regarding consent for that field, has always been about consent obtained by the registrar for the registrar's processing of the data. We have NOT discussed the transfer, or logging of this consent by the registry, or how basic matters such as change of mind / article 17 / subsequent opt-out of the registrant would be properly notified, achieved or even legally arranged by the registry.
I therefore we do NOT support the additional line from the BC as written, a as it completely circumvents the discussion necessary to achieve GDPR compliance.
The Registries therefore will only support, at this time, the recommendation as was discussed, and that is one that concerns the direct relationship and consent of a registrant with the registrar. We therefore propose the following update as clarification.
After the implementation phase-in period, the ORG FIELD will no longer be REDACTED by the registrar.
NOTE: I will defer to my Registrar colleagues as to the assumptions of the remainder of the insertion.
Alan
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Alan Woods
Senior Compliance & Policy Manager, Donuts Inc.
The Victorians, 15-18 Earlsfort Terrace
Dublin 2, County Dublin Ireland    |
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