Comments on the initial report

[Joey Foo <joeyfoo@xxxxxxxxxxx>]

Dear ICANN:

Regarding the proposed rules governing companies that provide WHOIS privacy 
services (as set forth in the Privacy and Policy Services Accreditation Issues 
Policy document):

I urge you to respect internet users' rights to privacy and due process. 
Everyone deserves the right to privacy.


P/P services exist to protect their users against not just inconvenience, but 
even harm by organisations as well as dangerous individuals. Requiring weak, 
insufficient standards for disclosure of personal information will easily lead 
to users being harmed, and may potentially cause life-changing, irreversible 
damage to them.


Personal information, once released, cannot be easily retracted. No one’s 
personal information should be revealed without a court order. This is 
regardless of whether the request comes from a private individual or law 
enforcement agency. 


In addition, the user should, to the fullest extent possible, be allowed input 
on and be informed of any requests, and the outcome of such requests. They 
should also be made aware of alternative options apart from disclosure of 
personal information, where possible.


It is worth nothing that there are repercussions to requiring all domain names 
associated with commercial activity to not use P/P services, for example, small 
business owners running a business out of a home address. 


There should also be clear, specific definitions of “commercial” and 
“transactional” activities: are individual running a personal website with 
simple text-based ads considered such activities?


ICANN, as the overseer of the world’s domain name system, should respect and 
uphold the privacy of vulnerable individual and commercial users of the system.