New Accreditation and Disclosure Policies for Proxy Providers

[Karl Horky <karl.horky@xxxxxxxxx>]

Hello,

I have read now from multiple tech news sources about ICANN's plans to
eradicate online privacy through the new accreditation and disclosure
requirements for WHOIS info.

I strongly oppose this decision for the following reasons:

- This will have a chilling effect on freedom of speech online. If anyone
can obtain the WHOIS data just with a well-written letter, nobody running a
domain will have true privacy.

- Personal home address information does not belong in a registry on the
web. If an individual is savvy enough to register a domain, they can surely
set up and use an email address to reply to issues with the domain. This
email address can be the primary contact method of WHOIS records.

- The definitions of "commercial" and "transactional" activities are too
vague and encompass too many domain owners. If a personal blog owner were
to have ads or a small shop on their site, this would probably fall into
these categories. The idea behind this is more having to do with preventing
crime online, and should be done through the definition of categories of
crime that can trigger a disclosure of information (hacking, distribution
of malware, etc). Each single case with a request for publication should be
examined by an impartial technical third party to determine applicability.

- Domain owners should be notified of all cases of the publication of their
info.

There are most likely other areas where I would disagree with this new set
of policies as well, but not everyone has time to go through your huge
proposal document with a fine-toothed comb. Would be nice to have these
proposals written as a simple list, published somewhere wide in the open.
But of course, then you would get a lot more feedback.

All the best,
Karl