[At-Large] Data Protection directives need to include Data Transparency directives.

gtheo gtheo at xs4all.nl
Wed Aug 22 07:42:30 UTC 2018

A good read might be to check how the DPA's worldwide view this subject 
and it touches upon some of the issues you raise.

Best regards,

Theo Geurts

sivasubramanian muthusamy schreef op 2018-08-22 12:06 AM:
> Hello,
> (I sent the following message as comments on an epdp Report on
> Temporary Specification for gTLD registration data. But this is more
> of a comment on Data Protection regulation in general, so copied to
> the Internet Policy list)
> In Data Protection terminology, "Personal data" is more of a generic
> or 'loose' term that applies both to individual and business data. In
> DNS, Registration Data does not make any distinction between
> individual registrants and business registrants whose web space is for
> some form of (e)commerce activity. While there is a need for privacy
> of personal data of individual registrants, the opposite, need for
> greater transparency, may be required in the case of data related to
> any form of commercial, perhaps even Government and non Government web
> spaces.
> The rationale is that the online presence of small and large
> businesses alike are often short of information pertaining to physical
> location, names of functionaries, officials or the person in-charge.
> A Phone company does not have listed phone number, an email company
> does not have a visible email addresses ! This is part of a pattern of
> multiple players transacting business online from a carefully guarded
> climate of "do-not-reply" email accounts, phones without a call back
> number, answering machines, conveniently assisted by BPO
> intermediaries who keep the consumer at an unapproachable distance. A
> hotel reservation portal or a small shop online transacts business
> online without allowing the consumer the ability to reach them for
> various reasons.
> Limiting access to Registration data indiscriminately and only for
> 'legitimate uses' may perpetuate this trend of inaccessibility of
> business entities,  widen the disconnect between business and consumer
> with the effect that multiple commercial registrants would continue to
> design their online presence to transact business without due
> accountability. The section  4.4.2, Lawfulness & Purposes of
> Processing gTLD Registration Data as written, might have the
> unintended consequence of perpetuating unhealthy protection for
> segments that actually require information disclosure and
> transparency. How the DNS will make such a distinction is another
> question.
> Does GDPR make such a distinction?
> Sivasubramanian M
> Sivasubramanian M [1]
> twitter.com/shivaindia [2]
> Links:
> ------
> [1] https://www.facebook.com/sivasubramanian.muthusamy
> [2] http://twitter.com/shivaindia
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