Subdelegation/federation of whois (or rdap) servers could solve the problem. 
Whois still would remain effectively unstructured and unparseable but that’s 
the status quo. It would require entities to set up another public facing 
service. 

That’s an approach, I can’t say its wrong. My philosophy here was to design 
something using services people already run with functionality that already 
exists. Since SPF, DKIM, DMARC, CAA already live in DNS, it seemed appropriate 
to put this there too. 

My thoughts here were to keep it simple, use existing stuff, and have it all be 
voluntary disclosure and allow role-based info. That’s not the only approach. 
It just seemed logical to me to tackle it that way. 

—
John Bambenek

On July 1st, 2019, my DGA feeds are converting to a CC-BY-NC-SA 4.0 license 
which means commercial use will require a license. Contact 
sa...@bambenekconsulting.com for details

On Jul 10, 2019, at 08:48, Philip Homburg <pch-dnso...@u-1.phicoh.com> wrote:

>>> As far as I know, there is no issue with whois and the GDRP when it comes
>>> to voluntarily publishing information in whois.
>> 
>> Nope. Its OK for you to publish your Personal Data. For anything
>> else, you need to get informed consent first. And be able to prove
>> that. And give the Data Subjects the ability to modify those data
>> or get them deleted.
> 
> When you register a domain, your registrar already has to have your informed
> consent to process any PII you supply. And as far as I know,
> registrars routinely ask for your name and credit card.
> 
> So all GDRP-related processes are already in place.
> 
> Looking at it from a technical point of view, whois has a referal mechanism.
> So if GDRP compliance would be a big issue, then allowing the handful of
> people who wish to publish anything in whois to run their own whois server
> would also solve the issue.
> 
> 
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