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Re: Proposed Specification on Proxy/Privacy Services

  • To: comments-proposed-raa-07mar13@xxxxxxxxx
  • Subject: Re: Proposed Specification on Proxy/Privacy Services
  • From: Moritz Bartl <moritz@xxxxxxxxxxxxx>
  • Date: Wed, 10 Apr 2013 11:02:29 +0200


We are not yet an ICANN-accredited registrar. I know the formal deadline
for comments is over, but I still want to express my worries
specifically about the proposed specification for proxy/privacy services.

As you probably are aware, the European Privacy law is very strict, and
in general limits the amount of customer data you are allowed to collect
to data that is required for billing purposes. Even forcefully
collecting for example a phone number, or even an address where it is
not needed, is prohibited.

Since it is already widespread practice to simply violate these laws,
and most people and citizen have given up on fighting for their privacy
rights, I am even more worried about section 3.3.2: You want to force
privacy registrars to submit a copy of all customer data to the ICANN or
an escrow service. Since 3.2.2 already requires registrars to react to
abuse complaints "24 hours a day, seven days a week", I really don't see
why this is necessary. Again, this is very likely against European
privacy laws, and apart from that me as a registrar would want the
assurance and ability to check on the escrow service's handling of data,
and require it to be in my country or a country of my choosing. The way
3.3.2 sounds right now makes me believe that obviously, some law
enforcement is interested in that customer data regardless of national law.

I urge you to completely drop 3.3.2.

Thank you for reading my comment,

Moritz Bartl
A concerned EU citizen and domain reseller

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