Privacy, Data Protection and the GDPR as
it relates to the .AS Domain Registry (V 1.0)
Introduction
The European General
Protection Regulation comes into effect for most of Europe from 25 May 2018.
Historically, the .AS Domain
Registry has maintained a strong privacy-oriented policy since we began operation
in June 1997. We have never shared our
zone file with third parties, including ICANN or the IANA. We have never sold Registrant,
Administrative, Technical, nor Billing contact information to third parties.
Additionally, we have limited
sharing of our data to the maximum extent possible. Generally, when asked for such information,
the Registry’s response has almost always been “No.” There are exceptions to this of course, both
in the past and continuing forward subsequent to the implementation of the GDPR,
as, for example, when executing a transfer of a domain from one Registrar to
another, or in response to a request from law enforcement back-stopped by a subpoena.
We will continue this policy
of minimal data sharing to third parties when the GDPR comes into effect.
Changes to “whois”
The Port 43 “whois” will further limit what little information that we
have always provided, blocking the Registrant’s name if the Registrant is a
person rather than a Corporate entity.
The web based “whois”, available at https://www.nic.as,
will also block the Registrant’s name in the case that the registrant is an
individual, rather than a Corporate entity.
Use of your Data
In the course of registering
domain names, we do store or process personal information. Personal data is defined as information that
relates to an identified or identifiable individual.
So how do we treat and
process your personal data?
Here are a couple of
examples.
If you make a payment to us using
a credit or debit card, you have to provide us with your name, the billing
postal address of your credit or debit card, as well as some additional
information that is required for us to successfully have our bank process your
payment. In this case, your credit or
debit card details are passed from us to our bank so that they can process your
payment.
If you are associated with a
Registration (either as the Registrant, or any of the Administrative,
Technical, or Billing Contacts), we need to collect some personal information
about you, such as your name, address, telephone number and email address so
that we can contact you about the domain name if we have to, and also to be
able to verify your identity if you contact us.
Your Rights
You can ask us at any time to
let you know:
(a) What personal information we possess
(b) How we
specifically process this information
and we will provide you this explanation. This information will be provided via
registered postal mail for security purposes once we have verified your
identity and recipient postal address.
You also have the right to
request an explanation from us regarding:
(a) The purpose of the processing of your personal data
(b) The categories of personal data that we hold
(c) The recipients or categories of recipients to whom
your personal data has been or will be disclosed to
(d) The time period for which we expect to store your data
and whether or not we take any decisions automatically on the basis of your
personal data
You also have the right to
request that we correct, erase, or restrict processing of the data about you in
our possession, subject to the requirements regarding the minimum amount of
data we must hold in order to maintain a valid domain registration.
You may also ask us to inform
you about the source of the data, which will usually be from you yourself, your
agent ("registrar") or your company (if listed as a contact person
for them).
Lastly, if you remain
dissatisfied with anything related to how we are holding or processing your
personal data, you may lodge a complaint with the appropriate Data Protection
Authority.
If you have questions or
concerns regarding our data privacy policy, please email the Registry at registration-staff@nic.as with the
subject line beginning “GDPR Question”.