From:           Metaname
Received:     6 October 2015

Why .nz registrant data should /should not be collected

We feel that .nz registrant data ( along with all existing data collected such as admin and technical contact details) should be collected as it is currently. The release is an example of the need for the registry to hold these details. Metaname holds the DNC and NZRS in high regard as an organisation with the moral integrity required to be trusted to hold personal details. The attractiveness of .nz as a great place to do business depends upon that trust being maintained.

Why .nz registrant data should /should not be publicly available

.nz registrant data should not be publicly available since registrants are ( generally) either uncomfortable with the public disclosure of their details, or unaware of it and then uncomfortable about it when they find out about it. "Uncomfortable" in this case being a polite euphemism. Let's remember that registrant details include a phone number and a postal address as well as a name and e-mail address, all of which are required to be accurate. The unfettered and un-tracked access to information by unknown third parties ( unmitigated by existing technical measures viz. rate limiting on an IP per day basis) undermines trust in the .nz space. A change in policy will send a clear message that the DNC takes registrants' privacy seriously and thus will build trust in .nz.

Why the display and availability of .nz registrant data should / should not be the same for all parties

Metaname has heard from NZ businesses operating within the Internet space that having access to registrant details is sometimes useful and that they would like to enjoy continued direct access to such information. As such, we would encourage the discussion of measures that would allow such continued access on a white list basis on the understanding that any abuse of the privilege or failure to provide a duty of care can result in temporary or permanent revocation of the privilege without appeal at the discretion of the DNC. Any such discussions should cover measures necessary for abuse to be tracked back to a particular access account and a clear path for registrants to be able to report potential abuse. We recognise that this is difficult to accomplish reliably and feel that the need for such access is secondary to the need to protect registrants' privacy.

Why the current approach does / does not raise concerns for some

The current policy of publishing registrant details erodes public trust in .nz domain names and by association the DNC. Other TLDs such as .com and many new gTLDs offer WHOIS privacy and while Metaname does not support or endorse such privacy services, which we hold in low regard, registrants and resellers tell us outright that the current policy is the reason that they or their customers choose not to hold a .nz domain name. The current policy is therefore detrimental to .nz market share globally and should be amended.