Latvia’s ccTLD Plans “Data Minimisation” to Comply With GDPR

There’s a bit of a belated rush by European country code top level domain (ccTLD) operators to comply with the looming deadline to implement the .E.U.’s new privacy rules, the General Data Protection Regulation (GDPR). The latest is Latvia’s ccTLD, .lv who, in their announcement, said they plan “to implement data minimisation” to comply. And they are seeking comment on their plans by 12 April.

The data minimisation planned by NIC.LV to comply with the GDPR means that when registrants fill out the .lv domain name registration form, only one postal address will be required (instead of two) and no fax number will be required.

At present, if the domain name registrant is an individual, their first name, surname, personal identity number and postal address is not publicly shown. In the future, to ensure GDPR compliance, the holders’ telephone number and email will also not be published. In order to provide some communication channel with the domain names’ holder, NIC.LV will develop an electronic contact form.

The NIC WHOIS policy [pdf] has been prepared to determine the obligations of the NIC.LV and the WHOIS user, including the allowable use of WHOIS.

To ensure GDPR compliance and adaption to local regulations, NIC.LV proposes to change the terminology definitions and procedures. As this policy is being used for direct registrations, as well as registrations through registrars, NIC.LV proposes to make a separate document called the price list and payment policy of NIC.LV [pdf], which would apply only to direct registrations.

Information for domain name registrants on the processing of their personal data – access, data portability, rectification, deletion, etc. will be included in the updated NIC.LV Privacy policy [pdf].

In accordance with GDPR Article 28, the agreement between the Registry and the Registrar will be supplemented by Annex 3 “Personal data processing” [pdf], which will define the roles and responsibilities of the Personal Data Controller (NIC.LV) and the Processor (Registrar).

NIC plans to develop new documents:

NIC plans to make amendments to the following:

The NIC.LV feedback period is open until 12 April with comments to be sent to legal@nic.lv. All amendments to contracts and policies have also been sent to the Ministry of Transport for evaluation.