On Tue, Aug 22, 2023 at 4:54 AM Mario Loffredo
<mario.loffr...@iit.cnr.it> wrote:
>
> [ML] Firstly, would say at the outset that the authors and the WG have never 
> thought of this feature as uncontrolled whereas it is based on the use of 
> sensitive information.
>
> But, if on one side there are the privacy concerns to consider, on the other 
> side there are some legitimate interests to pursue.
>
> The reasonable compromise is to make the RDAP reverse search based on PII 
> accessible only to authorized users who are supported by lawful basis.
>
> For example, allowing the reverse search based on domain-entity relationship 
> to registrars users but solely on their own domains and contacts.
>
> Such a concept is summarized in the following sentence of Section 13:
>
>    In general, given the sensitivity of this functionality, it SHOULD be
>    accessible to authorized users only, and for specific use cases only.
>
>
> SHOULD has been used instead of MUST for two main reasons:
>
> 1) The document describes a generic reverse search query model. Therefore, 
> there might be reverse searches that are based on public information.
>
> 2) Provided that I don't have a legal background but, either when PII is 
> used, think we can't exclude implementations of this feature that are 
> publicly accessible and are still compliant with laws or regulations that 
> restrict the use of PII.

The email addresses and full names are not necessarily PII. They can
be, but they can also be related to role accounts and organizations as
a whole.

-andy

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