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Letter from Hansjürgen Garstka to Stuart Lynn Regarding Whois Issues

International Working Group
on Data Protection
in Telecommunications

Mr. Stuart Lynn
President and CEO
Internet Corporation for
Assigned Names and Numbers (ICANN )
4676 Admiralty Way, Suite 330
Marina del Rey, CA 90292-6601

675.25.9 15 January 2003

Interim Report Of The Names Council's WHOIS Task Force Of October 14, 2002

Dear Mr. Lynn,

I am chairing the International Working Group on Data Protection and Telecommunications.

The Group has tried to play an active role in the privacy-friendly development of the information society for quite some time. The Group was founded in the framework of the International Conference of Data Protection and Privacy Commissioners in 1983. It consists not only of representatives from national and international data protection organisations, but also of independent scientists and other specialists in privacy and telecommunications. The Group issues common positions and working papers on data protection and privacy problems in the telecommunications sector. Since 1996 one of the main subjects that the Working Group has been dealing with are data protection and privacy matters regarding the development of the Internet.

An overview of the work of the Working Group is available from the website of the secretariat of the Group at

At its last meeting on 11-12 November 2002 in Berlin the Working Group has discussed privacy matters regarding the proposed modifications of the WHOIS policy in the Interim Report Of The Names Council's WHOIS Task Force of October 14, 2002. The Working Group has already dealt with privacy and data protection aspects of the registration of domain names on the Internet in a Common Position adopted at its 27th meeting on 4-5 May 2000. Please find attached a copy of the Common Position for your information. The Common Position is also available on the Internet at http//

At its meeting in November 2002 the Working Group has reaffirmed the recommendations given in its Common Position.

In this respect the Working Group is especially critical of proposals contained in the Interim Report of the Names Council's WHOIS Task Force to extend the search capabilities of WHOIS databases to searches for the registrant name. We can not see a plausible reason for such an extension of the search capabilities of the WHOIS databases which would at the same time create an additional risk to the privacy of the registrants of domain names.

I would be obliged if you could take these comments into account when reshaping ICANN's WHOIS policy. Should you have any questions regarding this letter or about the work of our Working Group in general, please do not hesitate to contact me.

Yours sincerely,

Hansjürgen Garstka


Berliner Beauftragter für
Datenschutz und Informationsfreiheit
Pallasstr 25/26
D-10781 Berlin
Phone +49 / 30 / 7560 7809
Fax: +49 / 30 / 215 5050


The Working Group has been initiated
by Data Protection Commissioners
from different countries in order
to improve privacy and data protection
in telecommunications and media
Domain Name System
Internationalized Domain Name ,IDN,"IDNs are domain names that include characters used in the local representation of languages that are not written with the twenty-six letters of the basic Latin alphabet ""a-z"". An IDN can contain Latin letters with diacritical marks, as required by many European languages, or may consist of characters from non-Latin scripts such as Arabic or Chinese. Many languages also use other types of digits than the European ""0-9"". The basic Latin alphabet together with the European-Arabic digits are, for the purpose of domain names, termed ""ASCII characters"" (ASCII = American Standard Code for Information Interchange). These are also included in the broader range of ""Unicode characters"" that provides the basis for IDNs. The ""hostname rule"" requires that all domain names of the type under consideration here are stored in the DNS using only the ASCII characters listed above, with the one further addition of the hyphen ""-"". The Unicode form of an IDN therefore requires special encoding before it is entered into the DNS. The following terminology is used when distinguishing between these forms: A domain name consists of a series of ""labels"" (separated by ""dots""). The ASCII form of an IDN label is termed an ""A-label"". All operations defined in the DNS protocol use A-labels exclusively. The Unicode form, which a user expects to be displayed, is termed a ""U-label"". The difference may be illustrated with the Hindi word for ""test"" — परीका — appearing here as a U-label would (in the Devanagari script). A special form of ""ASCII compatible encoding"" (abbreviated ACE) is applied to this to produce the corresponding A-label: xn--11b5bs1di. A domain name that only includes ASCII letters, digits, and hyphens is termed an ""LDH label"". Although the definitions of A-labels and LDH-labels overlap, a name consisting exclusively of LDH labels, such as"""" is not an IDN."