New European Data Protection

The new European General Data Protection Regulation (GDPR) is coming into effect on May 25, 2018. The main change will be that per default we will no longer disclose personal data.

    The Benefit

    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 have a better understanding of how, by whom, and why their personal data is processed, and how to take action against incorrect or illegal processing.

    Processing Data

    Processing of private data will be limited to a certain extent, especially regarding 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.

    Reduced publication and transmission of Whois Data

    Publication and transmission of personal data will be reduced as summarized below.

    Reduced Data provision by our Whois server

    The contact data provided by our Whois server only includes data of domains managed by us in so called “Thin” Registry TLDs, like .com/.net/.cc/.tv/.jobs. To comply with GDPR requirements, Key-Systems will reduce publication of contact data in Whois to only a few fields. All other fields will be redacted or replaced.

    Reduced Data transmitted to TLD Thick Registries

    Contact data transfer to TLD Thick Registries (like .info, .org, .xyz, etc.) will be reduced to only a few fields as well unless we can be certain that both data transfers as well as the GDPR compliance measures taken by the Registry Operator are in full compliance with the GDPR.

    Opt-in to disclose data

    An Opt-in to disclose data will soon be made 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 whether he wishes his data to be disclosed in the Whois for a particular contact handle.

    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.

    Contact to an undisclosed entity

    As the email address is no longer shown in Whois, we will introduce the possibility to contact the registrant through a web form. Inquiries sent through this form will be sent to the respective contact of record.

    The individual link to the web form will be published in Whois, typically in the “Email”-Field.

    Transfers from and to other registrars

    We currently envision that contact data should be made available for certain purposes, in particular transfers from and to other registrars. This would allow data transmission for transfers. However, this matter is still subject to additional reviews and may be changed accordingly.

    Stating contact handles for incoming .com, .net, .cc and .tv transfers

    While it is planned to transmit contact data automatically from other registrars, we cannot make sure that contact handles are transmitted properly.

    This particularly affects so called thin registry TLDs, amongst them .com, .net, .cc and .tv.

    Data in ccTLD Whois

    ccTLD Registries operate their 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.

    Technical implementation will go live May 22, 2018

    Our technical implementation will go live May 22, 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, .shop, .beer.

    On this day we will start to reduce Whois information of all contacts as described above.

    Whois Privacy

    Whois Privacy will continue to be fully available even after GDPR has become effective.