EPDP policy issues

[Mueller, Milton L]

Farzaneh:

The one thing I want to prevent when it comes to legal and natural distinction is to enable some stakeholders to use the distinction as an excuse for making more registrants data public and accessible.

Of course that is the motive, everyone knows that. That’s why the L/N issue serves as a space for what might ultimately lead to a compromise. If “some stakeholders” can get access to more data, but the data is not the kind of private data we care about, we can come to an agreement.

I was concerned about the registrants being obliged to identify themselves as legal or natural persons. This would have been worrying. You are saying that they are not obliged to, which is good, but some registrars want to make that distinction.

Yes, that is the key difference. I do not want third parties (registrars or registries) making the distinction for our registrants. Stephanie says she doesn’t either, but either she has changed her position or there is some twist in her argument that registrants cannot make it for themselves, that I do not understand.

I think the one solution would be that the registrar should not punish a registrant that does not respond to the question about being a legal or a natural person and always consider someone who doesn't respond to the question, a natural person. Have you discussed this, is it possible?

My proposal covers that. The choice would not be: Are you Legal or Natural, pick one? It would be
Do you choose to identify yourself as a Legal person, or not? In other words, by not declaring as legal, you are not necessarily asserting that you are natural (you might be a home office or a one-person business or a sensitive data group) – you are just saying you don’t want the RDS to treat you as a legal person.

--MM

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