I do not object.

--c.a.

-----Original Message-----
From: Milton L Mueller <[log in to unmask]>
To: [log in to unmask]
Date: Wed, 27 Jun 2007 10:07:04 -0400
Subject: Re: [NCUC-DISCUSS] Draft comments to support .TEL's Whois
proposal - due 6/28

> Thanks so much, Kathy! Does anyone object to putting in these
> comments on behalf of NCUC? 
> 
>  
> 
>    _____  
> 
> From: Non-Commercial User Constituency
> [mailto:[log in to unmask]] On Behalf Of [log in to unmask]
> Sent: Tuesday, June 26, 2007 11:31 PM
> To: [log in to unmask]
> Subject: [NCUC-DISCUSS] Draft comments to support .TEL's Whois
> proposal - due 6/28
> 
>  
> 
> All, 
> 
> I have not yet seen any comments circulated among us to support
> Telnic's proposal to modify its Whois publication consistent with the
> data protection laws of the UK and EU.  
> 
>  
> 
> Telnic is in exactly the situation we have always feared:  ICANN
> rules (adopted in the US decades ago) force publication of all
> personal data, but the UK and EU laws give the individual control of
> this data and make illegal its publication without the individual's
> consent.
> 
>  
> 
> This is an important opportunity for our constituency.  I have
> drafted some short comments below.  Thanks for your review.  Due to
> time considerations (including that I am swamped), please send
> specific changes, additions and edits if you have them.  Comments due
> 6/28. Public notice at HYPERLINK
> "http://www.icann.org/announcements/announcement-07jun07.htm"http://w
> ww.icann.org/announcements/announcement-07jun07.htm.
> 
>  
> 
> Regards and thanks to all the meeting,  
> 
> Kathy Kleiman 
> 
> ---------------------------------------------------------------------
> -----------------------
> 
> The Noncommercial Users Constituency fully supports the proposed
> changes of Telnic to the registry agreement as consistent with the
> laws of the United Kingdom and the European Union.
> 
> Telnic’s proposal to modify the data displayed to the world of its
> registrants, especially individuals, takes into account the legal
> requirements of the UK Data Protection Act of 1998 and the EU Privacy
> Directive.  These laws of a country and a continent provide rights to
> individuals which allow them to control the distribution of their
> personal data.  Individuals cannot have their address, phone, fax and
> email published without their express consent. 
> 
> Telnic has handled this matter properly.  It has consulted with the
> UK Information Commissioner's office which oversees and enforces data
> protection laws in the UK.  Its proposal follows the example of
> Nominet, the UK country code, which has a Whois policy that allows
> .UK registrants to protect their personal data.  It also follows the
> example of the Global Name Registry, incorporated in the UK and the
> first sponsored gTLD to seek to modify the gTLD Whois requirements to
> better protection personal data under law.
> 
> It is a completely unacceptable to ask a registry to violate civil
> and criminal laws as a condition of operating in the ICANN community.
>  It is a Catch-22 the Whois Working Groups and even the GAC have
> expressed concern over many times. Telnic wisely chose the proactive
> approach – to seek compliance with both ICANN contractual
> requirements and the UK and EU laws. It is an important request.
> 
> The NCUC strongly supports the grant of Telnic’s request as
> consistent with good business practices,  fostering corporate
> compliance with national law, and making clear that “gTLD Whois
> services must comply with applicable national laws and regulations”
> [GAC communique of Whois
> 
> We ask that ICANN adopt the Telnic proposal with alacrity.
> 
> The Noncommercial Users Constituency 
> [Date of transmission to ICANN]
> 
> 
> 
> 
> 
>    _____  
> 
> See what's free at HYPERLINK
> "http://www.aol.com?ncid=AOLAOF00020000000503" \nAOL.com. 
> 
> 
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