March 12, 2018

Accreditation & Access Model For Non-Public Whois Data

External Article

This article is hosted away from the Winterfeldt website at

The attached comments and draft model, submitted to ICANN CEO Goran Marby and GAC Chair Manal Ismail, address the need for development and implementation of an accreditation model to enable access to non-public WHOIS data for legitimate cybersecurity and intellectual property/consumer protection purposes. This model would need to be in effect at the same time that ICANN’s GDPR model goes into effect, in connection with the implementation of the GDPR on May 25, 2018.


The specific requests are to:


  1. facilitate rapid finalization and implementation of a model in a very short period time
  2. contract with appropriate parties (e.g. parties who crafted TMCH) to develop detailed specifications
  3. execute upon implementation of those specifications in advance of 25 May 2018


The comments and model were submitted to ICANN on March 13, 2018 by the following signatories:



DomainTools, LLC

Facebook, Inc.

LegitScript, LLC


Microsoft Corporation

Secure Domain Foundation

Time Warner, Inc.

download this document as a PDF