On the proposed guidance

[Stephanie E Perrin]

I actually think that since the contracted parties carry the liability 
for making a mistake in this distinction, the registrars should be able 
to overrule the registrant.  This is particularly important if the 
jurisdiction where the data is held respects the rights of employees to 
protect their personal info, whilst the person registering the domain 
name on behalf of the company/org may be unaware of that situation.

this is a very complex question and I do not support encouraging small 
entities to attempt to answer it.  It is heaping added legal costs on 
the folks we purport to represent.

Stephanie Perrin


On 2021-03-24 11:12 a.m., Mueller, Milton L wrote:
>
> I was reading through two documents setting out in detail the proposed 
> guidance on legal/natural.
>
> There seems to be more than one Google doc on this and I am not sure 
> which one is the latest or most official, though I suspect it is the 
> one with various people’s comments crawling all over it.
>
> I was pretty supportive of the Guidance overall. I had one problem 
> with it, though.
>
> I liked the description of HOW the differentiation needed to take 
> place. But in describing WHEN differentiation takes place and WHO 
> would do it, it sets out 3 “high level scenarios”.
>
> The first two are ok. The third scenario (listed as #5 in the 
> document) is that the Registrar does it for the RNH, based on 
> “inferences.”
>
> That option just doesn’t fly for those of us representing RNH’s in 
> this process. We cannot have a registrant’s disclosure status or 
> person type determined FOR them by someone else. If we can strike that 
> part of the guidance, I think we can be on our way to a much broader 
> consensus.
>
> Dr. Milton L Mueller
>
> Georgia Institute of Technology
>
> School of Public Policy
>
> IGP_logo_gold block
>
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