[ALAC] Consensus Call: ALAC Comment on Draft Registration Data Policy

[Carlton Samuels]

While we have a go at this, we might wish to reflect on what this recent
CJEU ruling may mean in context.
Public Access to Information on Company Beneficial Ownership is a Violation
of Privacy According to the CJEU
https://curia.europa.eu/jcms/upload/docs/application/pdf/2022-11/cp220188en.pdf

Carlton

==============================
*Carlton A Samuels*

*Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround*
=============================


On Thu, 1 Dec 2022 at 10:44, Jonathan Zuck via ALAC <
alac at atlarge-lists.icann.org> wrote:

> ALAC Members:
>
>
>
> As you will recall, the ALAC recently approved the comment on the draft
> Registration Data Policy. At last week's CPWG meeting, it was suggested
> that we might be able to strengthen the section on Thick Whois based on
> recent information about the European Union NIS 2 Directive recently
> approved by the European Parliament.
>
>
>
> Alan has drafted such an addition and it was presented at this week's CPWG
> meeting. Those present agreed that it was a good addition. SInce the
> comment period has been extended until next Monday, there is still time to
> resubmit our comment.
>
>
>
> The addition does not change the intent of the original comment. It adds
> the paragraph: "Moreover, the recently approved EU NIS2 requires that
> registries and registrars publish publicly available data, and make
> available redacted data to legitimate users; AND that registrars and
> registries cooperate so that data does not need to be collected twice. That
> implies that if registrars are the prime collector of the data (as they are
> with gTLDs) that registrars must cooperate and provide registries with the
> data. NIS 2 notes that this obligation is sufficient legal reason for
> processing the registration data under GDPR Article 6.1(c). [NIS 2:
> Recitals 109-112 and Article 28]"
>
>
>
> With this email, I am initiating a Consensus Call of the ALAC to ratify
> this addition.
>
>
>
> The Consensus call will end at 23:59 UTC on Sunday, 4 November 2022.
>
>
>
> If there are any questions or comments, please direct them to either this
> list, to me directly, or to Alan.
>
>
>
> Although messages indicating support are welcome, they are not necessary.
> This Consensus Call will be deemed to have succeeded in the absence of
> significant opposition (greater than 20% as specified by ALAC RoP 12.3.3.1).
>
>
>
> Thanks for your immediate attention.
>
> Jonathan
>
>
>
> Jonathan Zuck
> Executive Director
> Innovators Network Foundation
> www.InnovatorsNetwork.org
> Main: +1 (202) 827-7594
> Direct: +1 (202) 420-7483
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