NCUC members Kathy Kleiman and Stephanie Perrin contributed to developing the NCSG’s comment on the Status Update from the Expert Working Group on gTLD Directory Services. In summary, the NCSG’s main issues concern:

Registrant Type – the introduction of a new field without rhyme or reason (mentioned only once in an appendix of the Initial Report) and yet one with enormous implications for organizations, individuals and companies operating in countries with Free Speech and Freedom of Expression laws (a large percentage of gTLD registrants).

Too Much Data – with so much centralization, and its incumbent security and speech risks, we would have expected the EWG to streamline the data to only that which is needed for the technical stability and security of the Internet (e.g., not physical address which can be obtained through due process after the technical crisis is handled). We hope we can see this streamlined data in the next version.

Unlimited Access to those with Credentials – we look at the proposals and to us, the appearance seems to be one of “unlimited all-you-eat-access” to the data once you have made it through the gate. That gate is not only for the investigative Law Enforcement representative, or the lawyer engaged in litigation, but to all within their organizations – including assistants, paralegals, and secretaries. We trust that is not the intent, as you are as aware as we are that insider abuse is a number one threat for most organizations with respect to confidential data. We comment further below re: the ongoing security concerns of this data, even to those with credentials. The right to access once must not become unlimited right to access repeatedly, as each case and need is different.

Read the NCSG’s complete comments.