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Information about the upcoming General Data Protection Regulation

03.05.2018 15:44

The GDPR (General Data Protection Regulation) = DSGVO (General Data Protection Regulation) comes into force on 25 May 2018. With this article, we would like to give you a brief overview of our plans on how to deal with some of the concerns that arise from the GDPR regarding the processing of registration data currently published in Whois and how this will affect the future Domain registration services.

 The benefit of GDPR
Privacy is about having control of your data and GDPR will ensure that private individuals have more control and information on how their personal information will be published and processed.

While compliance with the GDPR is challenging for all involved parties, it will ultimately help to protect private data of Internet users from abuse and misuse both by restricting processing and by improving security. It will also help users to get a better idea of how their personal data is processed by whom and why, and how to take action against incorrect or illegal processing.

Processing data in the context of GDPR

Processing of private data will be limited to a certain extent, especially with regard to its transmission and disclosure.

However, we do not control the processing of data on each instance. Where we act as mere data processor we need to follow lawful instructions of data controllers such as ICANN and the registries in order to be able to continue to provide our services to you.

This also means we will need to continue to request full contact data both for our own business purposes under the GDPR as well as the legitimate purposes of the data controllers, but we will restrict processing and data transfers as much as possible. Publication and transmission of personal data will be reduced as summarized below.

Reduced publication and transmission of whois data
Reduced data provision by our whois server: The contact data provided by our whois server only includes data of domains managed by us in so called “thin” registry gTLDs, such as .com, .net, .cc, .tv, .jobs. To comply with GDPR requirements, we will reduce publication of contact data in whois to only a few fields. All other fields will be redacted or replaced.

Reduced data transmitted to gTLD "thick" registries: Contact data transfer to so-called gTLD thick registries (such as .info, .org, .xyz.) will be reduced to only a few fields as well unless we can be certain that both data transfer as well as the GDPR compliance measures taken by the registry operator are in full compliance with the GDPR.

In particular the data coming from our whois server and transmitted to non-compliant gTLD thick registries will be reduced to:

For organizations (O-handles, if the "organization" field is filled out and no first, middle, last name is given):

  • Organization

  • Street

  • City

  • State/Province

  • Postal Code

  • Country

For private persons (P-handles, if no organization is given):

  • Country

  • State/Province

An Opt-in function to disclose data will be made available for all contact handles (Owner, Admin, Tech, Billing) in the near future. The underlying technical process is very similar to contact verification, i.e. the registrant will receive an email to approve or decline disclosure of her or his data in Whois. This will allow each individual contact holder to select for a particular contact handle whether he wishes his data to be disclosed in the whois.

Please note that even if a contact holder decides to disclose his details in our system, this does not mean that the registry controlling the Whois output will also disclose this data. Work is currently ongoing at ICANN to harmonize this approach.

 Contact to an undisclosed entity

As the email address is no longer shown in whois, we will introduce the possibility to contact the registrant through a web form. Inquiries sent through this form will be sent to the respective contact of record.

The individual link to the web form will be published in whois, typically in the "Email"-Field.

Transfers from and to other registrars
We currently envision that contact data should be made available for certain purposes, in particular transfers from and to other registrars. This would allow data transmission for transfers.

However, this matter is still subject to additional reviews and may be changed accordingly.
Data in the whois of ccTLDs

ccTLD registries operate own whois Servers and must individually comply with GDPR. We are currently in the process of reviewing the plans supplied by the registry operators to determine the individual approach for each ccTLD.

In some cases changes to our backend connection to ccTLD registries will need to be applied where we have determined that we will not be able to process and/or transfer data under the GDPR. These planned changes will not affect the handling of the ccTLDs in our external gateways, portals and APIs, i.e. we expect no "code-breaking" changes for our customers.

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