Reply to post: "The vast majority"...

Who had ICANN suing a German registrar over GDPR and Whois? Congrats, it's happening

T. F. M. Reader Silver badge

"The vast majority"...

I am not arguing against GDPR, for ICANN, or in favor of US laws superseding European or German ones. Not at all. Having said that, Tucows' argument that for "the vast majority" of registered domains owner, admin, and tech contacts are the same and thus there is no need to collect all three seems strange. Even if those are different only in a small fraction of cases, it seems to me there may well be reasons for them to be different, and thus they need to be collected for legitimate operational purposes.

E.g., imagine an organization that wants to register a .de domain. Someone else here has already pointed out that one needs to be in Germany and have a German address to do that. That's the "owner", right? However, for administrative purposes, e.g., billing, someone else, maybe the company's finance department in another country, should be contacted (surely you've provided a separate "billing address" many times). That's a separate "admin" contact then. And technical/operational issues are handled by a third party - hell, the organization may not even have IT staff but still needs internet presence. That's a "technical contact", separate again. It does not seem to be far-fetched at all...

The registration procedure may have checkboxes saying "use the above address as your admin/tech contact" to avoid duplication (IIRC, this is similar to what AMZN do when you buy something from them - there is a checkbox to indicate that the billing address is the same as the delivery address), but in principle it makes perfect sense to me that the three contacts are logically independent and all are needed to complete the registration.

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