I am always suspicious when someone acknowledges the actions of someone else is right, very reasonable for their position, is beneficial, has the resources, and yet encourages them to stop doing it. Everything only gets harder to change once GDPR is in place. But I am sure you knew that. Now is the ideal time to act. The convenience of ICANN, registrars and registries is NOT the concern here, the convenience of registrants in the concern. Back to the never ending lack of concern for registrants .... The "stakeholder" who actually is responsible for the success of the internet, but never seems to have a seat provided at the "round table". Why is that?

Concern for registrants and the safety of their private information is paramount. In fact, our registrants will always know what data would have been put in the whois, even if it is no longer public. I also consider the ability to opt in to publication as one of the first things that will have to be implemented, however there are certain liability concerns that will have to be addressed first. This is about the development of a system for third parties (not the registrants) to access this data however and should therefore be well thought out with input from all sides of the community, registrants and outsiders as well. Doing this when we do not even know the exact landscape and at a time when parts of the community lacks resources to contribute is problematic. Ultimately we need to answer these questions together: 1) Who is entitled to access to what data elements under which circumstances? 2) How do we prevent illegitimate access or abuse of access levels? 3) How would a system to ensure the above have to look like. Let us work on that together.

>This is about the development of a system for third parties (not the >registrants) to access this data however and should therefore be well >thought out with input from all sides of the community, registrants and >outsiders as well. We have that now. The purpose for reinventing the wheel is? >I also consider the ability to opt in to publication We have that now through proxy whois (opt out). The purpose for reinventing the wheel is?

Whois is not what I am describing as it is public. The system I describe would only permit access to those with legitimate interests that significantly outweigh the data subjects rights or those with legal rights to access this data. Registrants could also be part of this group, proper safeguards assumed. And offering an opt-out solution is not a valid implementation to the GDPR. The data subject must agree to the publication, freely and without precondition (or one of the other justifications under the GDPR have to apply).

>The system I describe would only permit >access to those with legitimate interests An individual whose domain is stolen has legitimate interest in the data, yet great difficulty proving their legitimate interest. Thus their rights in fact are not being preserved. Right now they must prove NOTHING. Just enter a domain name into Google and its scraping of various whois services presents whois and a "whowas" audit trail they need to prove their previous domain ownership. Assuming they chose not to use Proxy Whois. If they use Proxy whois, that is their choice, they have the right not to use whois as a tool of ownership. Now they will have no choice to publicly display ownership. In effect the law is unintentionally (I believe) removing that right. Its the current societal illusion that we must trade off security and privacy. That is a false choice. I can have my privacy by using proxy whois should I choose, or I may maximize my domain security by not using proxy whois. As an intermediary I can use a lawyer to register my domain and have my privacy and my domain security, yes at an additional cost. We are now being denied choice, someone else thinks they need to make my choices for me.

I think you need to get more engaged with all the people at ICANN claiming to represent you, the domain name registrants. ALAC, NCSC and the others. And if you are willing to invest the time, you can also get involved in policy making on an individual capacity. The doors at ICANN are open to those willing to invest their time.

The siren call of bureaucracy. When you participate in such organizations you are required to adhere to their terms, freedom is not part of the relationship. This is why I no longer participate in bureaucracies. It's that "box" that is the problem. I have seen it destroy the passions of many brilliant people, and there was a huge loss in every case. More vocal people need to be outside the box to tap the shoulder of those in the box when necessary. Every pearl started with irritation ... Microsoft, and others, are well known for walking away from bureaucracies, and their "standards", to move industries forward. This most powerful word: No Domain theft is going to get worse. I have my own registrar containing my domains, none of this even applies to me as I long ago saw where this was going. http://www.circleid.com/posts/20180330_icann_cannot_expect_the_dpas_to_re_design_whois/#12122 I am not trying to protect myself, I am protected. I'm trying to help others that I know will be negatively affected. After 20 years of watching domain theft occur, and helping others recover domains. The industry has addressed the issue of registrant privacy for the past 16 years. Facebook, an entirely different service with builtin conflicts of interest, did not address these issues. Now the bad apple is being allowed to ruin the good apples. The domain industry has not ignored this issue for the past 16 years: Privacy Whois.