WHOIS Pilot Study report - Danish comments
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 P Please consider the environment before printing this email.