[gnso-dow123] European Union view on Special Circumstances proposal
As a matter of general interest to this Task Force, I am forwarding a portion of a message sent to Vint Cerf on 12 March 2007 by Peter Scharr, Chairman of the Working Party on the Protection of Individuals with regard to the Processing of Personal Data (Article 29 WP). The entire message is posted at: http://gnso.icann.org/correspondence/schaar-to-cerf-12mar07.pdf "As regards the 'special circumstances proposal', it remains totally unclear how this proposal is related to the purpose definition on which the task force has grounded its work. The very narrow justifications for eligibility to not having data published seems totally unsatisfactory from a privacy perspective, and is only acceptable if limited to commercial users. It would clearly not be sufficient if also applied to private, non-commercial domain registrants." David |