This has nothing to do with the domain owner/operator. These are additional, superfluous contacts who are, by definition NOT the domain owner.

Those additional contacts, the administrative and technical contacts, are the ones you'll usually need to go to if there's a problem with or caused by the domain. The technical contact would be the one to go to for things like DNS and mail-server issues. The administrative contact would be my first choice for most non-technical issues as they'd be the one responsible for the day-to-day operation of the domain above the purely technical level. The registrant would normally be my last choice of contact (unless they're also the technical and administrative contact) unless possibly it's a legal issue like a trademark dispute. The only contact I can see that shouldn't be public is the billing contact because that's entirely between the registrant and the registrar and nobody else is affected by billing problems or disputes.

over 90% of the time they are the same as the owner and when they are not, they are most often the reseller, whose info is already displayed. this is simply "we have it. so we want it." these contacts are anachronisms of the old, netsol fax process. nothing more. they made sense when there was no automated registration. and in any event you need to focus on how they are legal under the GDPR and how consent can be obtained from individuals that are not parties.

>these contacts are anachronisms of the old Totally agree. GDPR forces review where there has been no obvious need for such review. They can all be tossed. Now that said, my fear here is there being a single email address associated with domain management. From experience its nice to have other emails in case access is lost to one, such as when registrars treat registrant and admin fields as equal. This is obviously not going to happen, but having additional registrant email fields available would be nice with the removal of the other fields. Or change the admin field to Registrant field "2", again I know this will never happen but there is a lot of benefits to doing this (a little added fault tolerance). I myself recently got "locked out" of a domain almost 20 years old as I deleted the email's domain long ago. I never had a reason to care, until I went to transfer it ..... DOH! What a mess that made.

If one requires a data subject to supply data that is not needed to perform the service, such consent is not freely given, and violates GDPR. The "my contract made me do it" excuse doesn't work anymore.

>data that is not needed Clear as mud. From the registrant there is *ZERO* "need" of anything more than a credit card number or bank details and a text string to technically manifest a domain name on the internet. Simple proof of that is Verisign only recently supporting contact objects, they don't need them. Nobody does technically ..... You pay for the domain and then the registrar tells you to kiss off and go away, retaining no record of your existence. That you have needs after that is your problem nobody else's. It is an extreme view, but its accurate, everything else is convenience for management not need. And we have DENIC: https://www.spamhaus.org/news/article/724/ongoing-abuse-problems-at-nic.at-and-denic The people dealing with spam seem to be expressing a need. But GDPR in this case is asymmetrical warfare. A pretty piece of paper with pretty writing on it says the spammer NEEDS privacy more than the people stopping spam NEED the spammers contact information. The never ending game of true chaos, who defines truth? Who defines need? NOBODY and EVERYBODY, so there is no definable truth or needs at all. And yet the statement you quote is based on the idea that we can know for sure, that there is clarity such that all parties agree. But it gets better as the customer, seeking professional services do to their own ignorance, gets a seat (threat of GDPR lawsuit) on the service providers board of directors telling them how to run their business (what we are seeing this very second) ..... The customer defines "needs" not the experienced professional, who was retained for their experience which is unwittingly rejected. Tucows versus ICANN is a great example, ICANN has zero experience managing domains (but they know how to tax them), and when its representatives where asked how many domains they personally had they dodged the question. Looking at history this lawsuit makes so much sense. The people in the trenches trying to get things done versus the bureaucrats telling them what they are supposed to be doing. I personally think there is ample evidence that there is need for a public whois server system that displays registrant contact information. And for those that choose not to participate privacy whois was available. Both "needs" could be simultaneously met versus playing the collectivist game suggesting everybody's needs are the same and nobody gets a choice on the matter. Time to return to my favorite 1985 Brazil quote, which just happens to be about needs and is very appropriate for GDPR: Sam Lowry: Excuse me, Dawson, can you put me through to Mr. Helpmann's office? Dawson: I'm afraid I can't sir. You have to go through the proper channels. Sam Lowry: And you can't tell me what the proper channels are, because that's classified information? Dawson: I'm glad to see the Ministry's continuing its tradition of recruiting the brightest and best, sir. Sam Lowry: Thank you, Dawson.