Re: Proposed Specification on Proxy/Privacy Services
Hi, We are not yet an ICANN-accredited registrar. I know the formal deadline for comments is over, but I still want to express my worries specifically about the proposed specification for proxy/privacy services. As you probably are aware, the European Privacy law is very strict, and in general limits the amount of customer data you are allowed to collect to data that is required for billing purposes. Even forcefully collecting for example a phone number, or even an address where it is not needed, is prohibited. Since it is already widespread practice to simply violate these laws, and most people and citizen have given up on fighting for their privacy rights, I am even more worried about section 3.3.2: You want to force privacy registrars to submit a copy of all customer data to the ICANN or an escrow service. Since 3.2.2 already requires registrars to react to abuse complaints "24 hours a day, seven days a week", I really don't see why this is necessary. Again, this is very likely against European privacy laws, and apart from that me as a registrar would want the assurance and ability to check on the escrow service's handling of data, and require it to be in my country or a country of my choosing. The way 3.3.2 sounds right now makes me believe that obviously, some law enforcement is interested in that customer data regardless of national law. I urge you to completely drop 3.3.2. Thank you for reading my comment, Moritz Bartl A concerned EU citizen and domain reseller Attachment:
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