Letter from Chairman of EU’s Article 29 Working Party on Data Protection Regarding Whois

“… As regards the “special circumstances proposal”, it remains totally unclear how this proposal is related to the purpose definition on which the task force has grounded its work. The very narrow justifications for eligibility to not having data published seems totally unsatisfactory from a privacy perspective, and is only acceptable if limited to commercial users. It would clearly not be sufficient if also applied to private, non-commercial domain registrants. …”

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