We would like to give you a short summary on our plans to address some of the concerns arising from GDPR with regard to the processing of registration data that is currently being published in the WHOIS and how this affects domain registration services in the future.
Key-Systems is currently working to ensure to comply with the new European General Data Protection Regulation (GDPR) coming into effect on May 25, 2018 and per default we will no longer disclose personal data.
We're switching our thick Whois (i.e. for .COM and .NET) to GDPR compliance on May 22nd 2018 beginning at 08:30 UTC. Additionally we're starting to replace and undisclose contact data for thick registries (all other generic TLDs).
For all TLDs which are not GDPR compliant and do not support or support replacement/undisclosure of contact data the respective appendix will be updated.
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 have a better picture on how their personal data is processed by whom and why, and how to take action against incorrect or illegal processing.
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 in every 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.
An Opt-in to disclose data is available for all contact handles (Owner, Admin, Tech, Billing). The underlying technical process is very similar to contact verification, i.e. the registrant will receive a mail 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 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.
Further details in the dedicated article Opt-in to Disclose Data in Whois.
ccTLD Registry 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.
Our Technical implementation will go live May 22nd 2018 for all generic TLDs that do not enforce publication of contact details (for example .BANK and .INSURANCE), including legacy gTLDs like .COM, .NET, .INFO and new gTLDs like .XYZ, .SAARLAND, .BEER.
On this day we will start to reduce Whois information of all contacts as described above.
Whois Privacy will continue to be fully available even after GDPR has become effective. Instead of displaying a link to a contact page in whois it offers the benefit of direct email forwarding and non hidden contact details of our Whois Privacy Service.
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