Regarding WHOIS privacy services.

[Adam Lewes <addm.lwws@xxxxxxxxx>]

*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.*

   - Everyone deserves the right to privacy. Article 12 of the Universal
   Declaration of Human Rights states that "[n]o one shall be subjected to
   arbitrary interference with [their] privacy."
   - These rules are harmful to trans people who wish to identify by the
   name they choose for themselves to align with their gender. To reveal their
   personal information could be extremely dangerous, considering the amount
   of abuse trans people receive both online and in real life.
   - This makes finding the personal data of those for vindictive purposes
   (i.e.: doxing) very easy, and makes vulnerable people targets for
   harassment, 'swatting <https://en.wikipedia.org/wiki/Swatting>', etc.
   - No one’s personal information should be revealed without a court
   order, regardless of whether the request comes from a private individual or
   law enforcement agency.
   - If one's information is needed for legal reasons (e.g.: the owner of
   said domain has broken international or domestic law), and if the owner of
   the domain uses a WHOIS privacy service, the information should only be
   revealed via court order.


*Private information should be kept private. *

To reveal the private information of millions of innocent folk due to the
comparatively scant amount of criminals is harmful to thousands of people
and organisations, and could potentially be dangerous.

The World Wide Web is a community of people of all kinds, and to impose
said rules onto WHOIS privacy services could be harmful to those who may be
vulnerable to abuse and harassment (e.g.: minors, activists, etc.), as it
makes the discovery of their personal information very easily available.

Thank you,
Adam Lewes <http://lwwws.com/>

💛