Last night, ICANN published its Interim GDPR Compliance Model for how to treat WHOIS data in light of the upcoming GDPR enforcement deadline this May. The Model can be found here. Basically, ICANN staff is saying that they will not enforce ICANN’s contractual obligations related to WHOIS against any registrar or registry that is following the Model.

The Model has sweeping ramifications for brand owners trying to enforce. It also has sweeping ramifications for registrars and registries who are trying to comply with GDPR by adopting the model.

Over the course of the next few days, I will look at the ramifications for both groups. Please stay tuned to this blog for more.