[NCUC-DISCUSS] EFF's comment on GDPR compliance models

[Arsène Tungali]

Thanks Jeremy for sharing this piece, it helps see the issue form another
eye and thanks for your analysis.

I personally i am in agreement with you that Model 3 is the best for now as
it is easy to implement and  it would discourage those who need to access
registrant's personal data to even consider the effort of looking for that
court order or the subpoena, therefore, registrant's data will continue to
be safe. I am hoping many of us agree with this as well.

Model 2, while it also requires some efforts for one to access registrant's
data (which is good IMO) but these efforts will be on ICANN's shoulders (or
rather to the data controllers) and i cannot imagine them being able to
work out such a certification model in the next few months and have it well
done. I am afraid if we consider this option, we will run the risk of
having something that will be quickly made with possible imperfections.

Model 1 is simply not the right thing to consider because it will be
difficult to distinguish/decide who has a legitimate reason. And anyone who
needs data will come forward and will present their reasons (which might
not be worth to gain access to personal data).

Being a non expert in this area, these are just thoughts and my little
understanding of this topic.

------------------------
**Arsène Tungali* <http://about.me/ArseneTungali>*
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2018-01-26 9:20 GMT-08:00 Jeremy Malcolm <jmalcolm at eff.org>:

> Since it seemed like the rest of NCUC favoured Model 2B, EFF has gone
> ahead and written its own separate submission to ICANN in support of
> Model 3.  It's attached to this blog post:
>
> https://www.eff.org/deeplinks/2018/01/europes-gdpr-will-
> force-icann-improve-whois-privacy
>
> --
> Jeremy Malcolm
> Senior Global Policy Analyst
> Electronic Frontier Foundation
> https://eff.org
> jmalcolm at eff.org
>
> Tel: 415.436.9333 ext 161
>
> :: Defending Your Rights in the Digital World ::
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