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Clause 6.1 concerns

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  These comments are with respect to the proposed Terms and Conditions at: http://www.nominet.org.uk/howto/tandc.doc

6.1 (c) Public Register Subscription Service (PRSS)

"[6.1] Personal data submitted by you will be.. [6.1c] Used as part of the Public Register Subscription Service ("PRSS") [..] The PRSS enables subscribers to perform WHOIS queries and reverse look-ups. We will publish your name and address but not your telephone or fax number or email address as part of the PRSS"

This does not explicitly state whether the private addresses of individuals who have opted out of whois will be on the PRSS, merely making reference to "WHOIS queries" implies that they will not, but this must be clarified such that no ambiguity exists.

6.1 (d) Providing personal data to third parties

The change being proposed allows Nominet to provide data to third parties "with a legitimate reason for requesting the information".

Please explain why this is required to be added. Nominet (in practice) already provides data to those requesting it (under what contract term does it presently do this??), and whilst the additional burden of a written request is welcomed, I don't see why this change is necessary if Nominet is already permitted to do this at present?

6.1 Changes of status

The clause "Please note that if at any point we discover that you are no longer a Consumer, we will automatically post your personal data onto the WHOIS in accordance with clause 6.1(b) above without further notice to you" is unfair. If an individual has an expectation of privacy, it is unfair to take this away without notifying them such that they may challenge the decision.

Sebastien Lahtinen



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