NCSG Statement on .cat proceeding

[Robin Gross <robin@xxxxxxxxxxxxx>]

The NCSG wishes to express its support for punctCAT's proposed amendment to 
allow natural persons an opt-out measure by which some WHOIS data would be 
withheld from public view.

At the same time, we do not believe the request offers the opt-out opportunity 
broadly enough to satisfy all legitimate privacy needs. The NCSG believes there 
are several types of institution that require similar opportunities to opt out 
from public display of their identity and address details.  Among those 
institutional types are organizations that:


* protect natural persons,


* deal with political freedoms,

* deal with religious freedoms,

* deal with sexual preference and expression,

* deal with political minorities,

* deal with religious minorities, and parents' groups that deal with children's 
activities such as sports teams, home-schooling and other childcare issues.

As the privacy of natural persons is protected within the EU Data Protection 
Directive, political parties and minority speech are protected within the 
privacy rules in other national laws. Given that gTLDs are global, it will be 
important to take all national laws into account.

The NCSG further expresses concern that law enforcement and third party access 
to the data should be consistent with due process protections. We urge 
development of these disclosure procedures in conjunction with the Community.


- Robin Gross, NCSG Chair