Tapani,

Thanks for this.  I believe that if we properly analyze the requirements for a revised and improved RDS, we should be able to meet the GDPR requirements as well as similar requirements elsewhere, and the result should serve the Internet community quite well.

Thanks,

Steve


On Fri, Feb 16, 2018 at 4:05 PM, Tapani Tarvainen <ncsg@tapani.tarvainen.info> wrote:
On Fri, Feb 16, 2018 at 10:52:51AM -0800, John Horton via gnso-rds-pdp-wg (gnso-rds-pdp-wg@icann.org) wrote:

> But we're seeing the registrar community say: We want to apply this
> globally. To all domain name registrations. Doesn't matter if the
> registrant is the intended beneficiary of the new law, or in scope,
> or not.

Intended beneficiaries of the GDPR are all the people in the world.

The recitals make that quite clear.

In particular EU wants to protect also non-European individuals
against European companies even if that would mean giving competitive
advantage to non-European companies, strange though that may seem to
some.

--
Tapani Tarvainen
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