In a previous blog post, I detailed our 23 April meeting with the Article 29 Working Party (WP29) Technology Subgroup in Brussels. This meeting was an important follow-up to the letter [PDF, 400 KB] that WP29 sent us on 11 April, and we remain appreciative of the opportunity to receive their feedback on the progress made in developing an interim compliance model.
It was clear after our meeting that a number of important questions still remained, and we agreed to provide a letter requesting additional input on how to bring the ICANN org and contracted parties into compliance with the law. That letter was sent to the WP29, and is available here [PDF, 564 KB].
We hope that the WP29's reply will provide us with greater clarity and guidance as we move forward.
Our ongoing dialogue with the WP29 has been a key part of our overall work to identify a model that will both maintain the current WHOIS to the greatest extent possible, while also complying with the European Union's General Data Protection Regulation (GDPR). It is important that we strike the right balance that allows us to both maintain a stable and secure Internet and comply with our bylaw obligations relating to WHOIS, while also ensuring compliance with the law.