On Thu, Jan 24, 2019 at 02:44:16PM +0100, Mario Loffredo wrote:
> Hi all,
> 
> Il 24/01/2019 13:19, Hollenbeck, Scott ha scritto:
> > > -----Original Message-----
> > > From: regext <regext-boun...@ietf.org> On Behalf Of Niels ten Oever
> > > Sent: Thursday, January 24, 2019 5:37 AM
> > > To: regext@ietf.org
> > > Subject: [EXTERNAL] Re: [regext] Call for adoption: draft-loffredo-regext-
> > > rdap-reverse-search
> > > 
> > > 
> > > 
> > > On 1/23/19 8:26 PM, John Levine wrote:
> > > > In article <0f07073e-9e96-3dee-2c39-9aef91dc9...@digitaldissidents.org>
> > > you write:
> > > > > There is also no limitation or specific use defined, which makes this
> > > protocol in direct violation of with the GDPR.
> > > > I'm sorry, but that assertion is not even wrong.
> > > > 
> > > > The GDPR affects entities that process or control data related to EU
> > > > people.  It is not about technical specifications that someone subject
> > > > to the GDPR might use at some future time.  It's up to the processors
> > > > and controllers to figure out if they're subject to the GDPR and if so
> > > > how their processing complies with it (keeping in mind that "consent"
> > > > is pretty low on the list of criteria.)
> > > > 
> > > > I don't plan to further engage with this unfounded line of argument.
> > > > 
> > > > For anyone interested in actual work, the ICANN EPDP on this topic is
> > > > grinding along and it seems reasonably likely that they will have sort
> > > > of reverse search, maybe plain text, maybe hashed identifiers so you
> > > > can ask questions like what are all the domains with the same contact
> > > > address as this one without knowing what the contact address is.
> > > > 
> > > I totally agree with John here: let's await what comes out of the ICANN 
> > > EPDP
> > > and see whether this is actually something that is warranted and build it 
> > > to
> > > that spec.
> > ICANN isn't the only potential user of this technology. I'd like to make 
> > sure that this draft can address any ICANN-specific use cases, but I don't 
> > think we should sit around and wait for one particular constituent to get 
> > its act together. Assuming that we have non-ICANN use cases to consider, it 
> > would make more sense to start work now and defer completion until we're 
> > comfortable that all anticipated use cases are addressed.
> > 
> > Scott
> 
> + 1
> 
> I believe that nobody here is thinking to a misuse of this technology.
> 
> Each RDAP provider implementing this capability is subject (like each WHOIS
> provider has been subject so far) to some law about personal data protection
> defining de facto the legal use.
> 
> If WG members agree that it is wothwhile for RDAP users, we should move
> forward and be sure that RDAP providers will rely on policies described in
> RFC7481 to control its availability, just in the same way people adopt
> security measures to control the access to systems, applications, services,
> and so on.
> 
> That being said, in order to avoid any misunderstanding, I'm changing the
> draft to better explain some permissible use cases.

I agree with both Scott and Mario here.

Additionally, the discussion on this list with Mario has satisified my
reservations, and I fully support the adoption of this document.

-andy

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