Re: [alac] DRAFT: Impact statement on WHOIS. COMMENT BEFORE TUESDAY.

[Vittorio Bertola <vb@xxxxxxxxxxxxxx>]

On Sat, 15 Feb 2003 16:54:50 +0100, you wrote:

>Please find attached a draft of an ALAC impact statement with
>regards to WHOIS policy.  We'll need to submit this by Tuesday.
>
>I've tried to keep this on a rather general level, by putting things
>into context and asking for further work on that topic. Please
>comment ASAP.

My first comments:

About the process through which accuracy complaints are handled by the
registrars: there should be guarantees that sufficient effort is made
by the registrar to contact the registrant prior to the domain being
put on hold. IMHO this should at least include:
- at least 1 telephone call to any phone number listed in registrant
data and contact persons data, during business hours in the
registrant's timezone;
- at least 1 e-mail to any e-mail address listed in registrant and
contact persons data;
- at least 1 postal letter to the physical address (even if it seems
unlikely to be true!) listed in the registrant contact.

Generally speaking: I think that we should try to make it more evident
that privacy protection mechanisms are to be implemented asap in
WHOIS. Each registrant or contact person should be free to hide partly
or totally his identity and personal data to the general public, and
in this case this information should be kept by the registrar and/or
registry (according to the registry model) and not disclosed to anyone
but official law enforcement agencies. This would automatically make
people much more collaborative in providing true data, and is the only
way through which accurate data can be ultimately obtained. And, by
the way, this is required by law in Europe.

I would even consider saying that no further steps should be taken
towards "WHOIS accuracy" until a privacy protection scheme can be
designed and deployed, but perhaps this could be a little too extreme.
-- 
vb.                  [Vittorio Bertola - vb [at] bertola.eu.org]<---
-------------------> http://bertola.eu.org/ <-----------------------