[PC-NCSG] Fwd: [NCSG-Discuss] Proposed public comment on .CAT WHOIS Proposed Changes

[Robin Gross]

Thanks, Wendy.  We put it out on this list as the draft consensus position (as has been done) and if no PC members object in the next day, we can send it in as our comment.

Thank you!
Robin


On Feb 16, 2012, at 2:02 PM, Wendy Seltzer wrote:

> What's our process to [see if we can] make this an NCSG comment?
> 
> --Wendy
> 
> -------- Original Message --------
> Subject: [NCSG-Discuss] Proposed public comment on .CAT WHOIS Proposed
> Changes
> Date: Thu, 16 Feb 2012 16:30:13 -0500
> From: Wendy Seltzer <wendy at SELTZER.COM>
> Reply-To: Wendy Seltzer <wendy at SELTZER.COM>
> To: NCSG-DISCUSS at LISTSERV.SYR.EDU
> 
> As we discussed on the NCSG call Wednesday, we had begun drafting a
> statement for the punctCAT public comment. On the call, we heard support
> for finalizing that statement and sending it in, despite being shortly
> past the comment period's closing.  Below, the statement for your review
> and approval. Thanks to Avri for coordinating a draft from which this draws:
> 
> ---
> 
> The NCSG wishes to express its support for punctCAT's proposed amendment
> to allow natural persons an opt-out measure by which some WHOIS data
> would be withheld from public view.
> 
> At the same time, we do not believe the request offers the opt-out
> opportunity broadly enough to satisfy all legitimate privacy needs. The
> NCSG believes there are several types of institution that require
> similar opportunities to opt out from public display of their identity
> and address details.  Among those institutional types are organizations
> that:
> 
> * protect natural persons
> * deal with political freedoms,
> * deal with religious freedoms,
> * deal with sexual preference and expression,
> * deal with political minorities,
> * deal with religious minorities,
> and parents' groups that deal with children's activities such as sports
> teams, home-schooling and other childcare issues.
> 
> As the privacy of natural persons is protected within the EU Data
> Protection Directive, political parties and minority speech are
> protected within the privacy rules in other national laws. Given that
> gTLDs are global, it will be important to take all national laws
> into account.
> 
> The NCSG further expresses concern that law enforcement and third party
> access to the data should be consistent with due process protections. We
> urge development of these disclosure procedures in conjunction with the
> Community.
> 
> 
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