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
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 http://www.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
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
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
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]
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