WHOIS Pilot Study report - Danish comments

[Finn Petersen <FinPet@xxxxxxx>]

The Danish Business Authority welcomes the opportunity to provide its  general 
comments to the WHOIS Pilot Study Report.

Firstly, we would like to thank ICANN for the briefing to the GAC in Singapore 
on the wide range of WHOIS-related activities currently underway. We would like 
to reiterate that it is of the greatest importance to ensure that all 
stakeholders, including governments, are effectively involved in this important 
work as many of the issues under discussion and analysis have public policy 
dimensions, including privacy, law enforcement, consumer protection and public 
safety. Especially taking into account the resources going into the current 
processes of the IANA transition and the related work on enhancing ICANN 
accountability where large parts of the community is involved. Moreover, we 
would like to refer to earlier GAC advice concerning WHOIS, including GAC 
Communiqués from Singapore February 2015, Los Angeles October 2015, and London 
June 2014 as well as GAC WHOIS Principles.

Secondly, with regard to the WHOIS Pilot Study Report, we believe that while it 
is important to examine the syntactic and operational aspects of WHOIS data 
validation, these aspects must be supported by exploring accuracy from an 
identity perspective in order to determine that WHOIS data corresponds to the 
registrant.

In the Danish Domain Act, which regulates the Danish ccTLD, there are rules 
concerning WHOIS data. The rules state that the .dk WHOIS database must be 
accurate and in order to achieve this the administrator of .dk must perform an 
identity check on the registrant before activating a domain name.

We are looking forward to continuing to working together with ICANN, including 
through the GAC, on these important matters.


Kind regards

Finn Petersen
Director of International ICT Relations

DANISH BUSINESS AUTHORITY

Dahlerups Pakhus
Langelinie Allé 17
DK-2100 København Ø
Telephone: +45 3529 1000
Direct: +45 3529 1013
E-mail: FinPet@xxxxxxx
www.erhvervsstyrelsen.dk

MINISTRY FOR BUSINESS AND GROWTH

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