[ncc-services-wg] @EXT: RE: 2018-05 New Policy Proposal (Publication of Legal Address of Internet Number Resource Holder)

I'm following this conversation, I understand the need, but I think that 
this proposal
ignores GDPR.

Publishing any persons' address falls under GDPR's protection.
Please have a look at:
https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-personal-data_en

If there is a certain way of identifying company vs personal data, then 
company data may
be published. But there will be trouble if the company's name is 
"FirstName LastName company"
as:

*What constitutes personal data?*
The GDPR applies to ‘personal data’, meaning any information relating to 
an identifiable person who can be directly or indirectly identified in 
particular by reference to an identifier. This definition provides for a 
wide range of personal identifiers to constitute personal data, 
including name, identification number, location data or online 
identifier, reflecting changes in technology and the way organisations 
collect information about people.

so
-1

regards

>
> I read the rationale of the proposal, and I understand how useful and 
> time saving it would be to have a tidy database. I like it.
>
> I am not against publising addresses, I am advocating good design in 
> the hope that the rights of a minority will be protected not less than 
> today.



-- 


Panagiotis SIKAS
Systems and Networks Group

Institute of Computer Science
Foundation for Research and Technology Hellas
email:sikas at ics.forth.gr
Tel: +30.2810391647
Fax: +30.2810391641

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