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In the current debate over the balance between privacy and Internet safety and security, one of the unanswered questions is: “How will those responsible for protecting the public interest gain access to the non-public data in the WHOIS databases post General Data Protection Regulation (GDPR)?”
In an attempt to prevent WHOIS data from going “dark,” several community members have been working for the past weeks to create a model that could be used to accredit users and enable access to the non-public WHOIS data. The submitted model seeks to help the ICANN community provide continuity for legal and legitimate access to non-public WHOIS data once ICANN’s proposed interim model (Calzone) is implemented. It’s intended as a first step to developing an implementation model before the May 25th deadline that would have minimal impact to the contracted parties who control their WHOIS databases while respecting the GDPR and protecting users.
The ICANN multi-stakeholder community welcomes comments on this model.
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You say “The ICANN multi-stakeholder community welcomes comments on this model.”
Questions:
Who at ICANN, specifically, has authorized you to speak on behalf of the “ICANN multistakeholder community” and solicit, on its behalf, public comments on this model?
Was this model drafted by one of ICANN’s cross-community working groups (CCWG) in accordance with the ICANN bylaws? If so, identify the CCWG. If not, please state who, specifically, drafted this model (version 1.1), by providing, specifically, the names (and affiliated organizations) of lawyers, lobbyists, and other special interest groups you are representing, or on whose behalf you are presenting this “model” (version 1.1) for public comment.
Where do I submit comments on your defective, incomplete model? You did not provide a link to any open public comment page at ICANN, or elsewhere, devoted to your “model” (version 1.1).
John,
I am not authorized to speak on behalf of any stakeholder. The Accreditation Model was drafted by representatives from business, corporations, organizations and legal experts. The model can be found on the ICANN GDPR Comment page. It’s now referred to as “AAM1” located here: https://www.icann.org/resources/pages/gdpr-legal-analysis-2017-11-17-en.