1. Only information necessary for the stated purpose of the WHIOIS database should be collected and retained, and

2. The stated purpose of the database should be crafted as narrowly as possible to meet the needs for technical management of the Internet. It is not the business of ICANN nor the registrars to serve the ancillary purposes of groups who may wish to have access to WHOIS information for their own unrelated needs.

These two principles are long-standing and fundamental to privacy law and regulation in many if not most of the nations served by the Internet, and ICANN policies need to respect these laws and regulations. To the extent there may still be open questions about the nature and coverage of these national policies, we would urge GAC, before it makes a final decision, to consult formally and extensively with national data privacy commissioners to get these laws and regulations interests clearly on the record.

We would note that libraries in many nations have had to vigorously defend the confidentiality of their patrons' information use. We are painfully aware of the potential dangers in collecting and retaining data about peoples' information use, as well as dangers inherent in the accommodating the demands of outside parties for access to such data. The Internet has increased both these dangers for users and pressures for access. Since libraries are integrally important in providing public access to the Internet, we would be most disappointed if ICANN ignored these basic privacy principles—as well as national laws—and unnecessarily put millions of Internet users at risk.

The American Library Association, the oldest and largest professional library association in the United States, has been a member of NCUC for many years. We look forward to continuing to work with ICANN to create a global Internet that serves the needs of the world community in a way that respects their dignity and human rights.

Sincerely,