Public Comment on 2013 RAA Data Retention Specification

["Rob Golding" <rob.golding@xxxxxxxxxxxx>]

I'm not sure why ICANN think a public comment period is necessary or called
for.

Data Retention and Data Protection Legislation is not 'open for public
comment' neither is ICANN qualified or in a position to decide what that the
legislation means - particularly when they have had it explained to them and
their 'lawyers' multiple times by multiple registrars

The Article 29 Group documents which have been with ICANN for *MONTHS* are
*VERY* clear and agreed by all the Data Protection entities of all EU member
states.

Neither ICANN nor 'the public' get to decide what laws the registrars have
to follow and they are making a huge and costly mistake if they consider
otherwise.

Just get on and grant the waivers rather than trying to wheedle your way out
of the ill-advised illegal clauses in the 2013 RAA !

Rob Golding
Astutium Ltd
UK based ICANN Accredited Registrar