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URS Recommendation #2

URS Recommendation #2

URS Recommendation #2

The Working Group recommends that URS Providers send notices to the Respondent by the required methods after the Registry or Registrar has forwarded the relevant WHOIS/RDDS data (including contact details of the Registered Name Holder) to the URS Providers. 


Context: 

Before GDPR implementation, URS Providers typically referenced the contact details of the registrants in the WHOIS/RDDS data in order to communicate with and transmit notices to the registrant. Providers also obtained contact information of the registrant via the Complainant and registrant’s website. 


Since the implementation of GDPR, personally identifiable information is masked in the public WHOIS/RDDS data. URS Providers rely on the Registries and Registrars to forward contact information and other relevant WHOIS/RDDS data of the registrant before they can send the registrant notices. 


Therefore, the Working Group proposed this recommendation as a result of GDPR implementation. This recommendation is also consistent with the EPDP Phase 1 Recommendations #23 and #27 (see footnote of URS Recommendation #1).