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ICAAN privacy policy

  • To: <comments-ppsai-initial-05may15@xxxxxxxxx>
  • Subject: ICAAN privacy policy
  • From: "Tim Davies" <tim@xxxxxxxxxxxxxxxxxxxxxxxx>
  • Date: Fri, 26 Jun 2015 17:03:41 +0700

Dear ICANN -


Regarding the proposed rules governing companies that provide WHOIS privacy
services (as set forth in the Privacy and Policy Services Accreditation
Issues Policy document):


I urge you to respect internet users' rights to privacy and due process. 

- Everyone deserves the right to privacy.

- No one's personal information should be revealed without a court order,
regardless of whether the request comes from a private individual or law
enforcement agency. 


I am not sure how much information you intend to publish without a court
order from the relevant country but if it includes email addresses this will
be a delight to spammers throughout the world. WHOIS gives this as one of
the major reasons to maintain privacy for domain owners. You can still
contact us through the domain registrar even with WHOIS guard. Whether I
choose to respond is down to me as it would be if you wrote to my email


If it is physical addresses that you wish to publish then I think that this
is also totally irresponsible since many people work from home. Do you
publish the home addresses of the people that run ICANN? Do you accept
people coming to your house to follow up business agreements or
disagreements? I am sure not.


Anyway how are you to police the addresses given? Do you have facility to
check addresses given are correct? I would imagine that there are numerous
ways to get around that especially amongst those committed to bad behaviour.


Private information should be kept private for personal safety and for
protection against crime. I fear that your approach will in fact do quite
the opposite of what you intend and offer the criminal element greater
opportunities to prosper.


Mistakes will be made. How will people damaged by your mistakes gain
compensation? Under what legal system do you make these global decisions
that affect people in all the countries of the world? Which court of law are
you answerable to if your actions cause me damage? If this information can
only be disclosed after a court action all these questions would be


Thank you.

Tim Davies

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