[ALAC] WHOIS Element Usage for GDPR Analysis

Alan Greenberg alan.greenberg at mcgill.ca
Thu Jul 13 00:25:09 UTC 2017


This is coming very late, but following Johannesburg I was swamped 
with non-ICANN issues and am trying to dig my way out.

As was discussed at the meeting, ICANN has (finally) woken up and is 
addressing the GDPR. As I understand it, as part of this, ICANN needs 
to get expert legal opinion and present a case to European data commissioners.

The first step is to identify how various parties use WHOIS data 
elements today. This is not an exercise in determining whether the 
particular elements are in fact "personal information" nor to 
determine if the usage is legitimate (under any particular rules). It 
is just to identify uses.

I am looking at this from three different perspectives:

1. User

2. Individual registrant

3. What I call user "tech support" - those of us who, for free or 
charge, help non-technical users and registrants solve their problems

Attached you will find.

A. Meeting notes from the introductory meeting held in Johannesburg

B. A list of WHOIS elements

C. Matrix Instructions

D. Usage Matrix ("User Stories") to be filled in.

I will send you what I have completed shortly.

I must submit it by the end of Saturday, so time is short.

Alan
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