Re: [registrars] Re: Credit Card Proposal

[Amadeu Abril i Abril <Amadeu@nominalia.com>]

Hi, all

Let me step for a few seconds with some wrods of advise for all those 
registrars established/doing business within the EU.

Before agreeing on any system that implies sharing information about 
customers, we should take adequate steps to "clen them" with both 
competiton authorities (if the agreement can be constructed as an 
incentive to collectivly reuse to deal with certain customers) and data 
protection authorities (if there is any degree of data sharing that is 
likley to identify the customers, one way or another). We have 
experiences here, both at the European level (antitrust) and national 
level (both antitrust and data protection) of participants to these 
agreements being fined.

Indeed, not all sort of agreements are illegal, far from that. But is a 
risky business, specially if you include identity information.

And I fully agree with Paul K: the time is still for putting pressure 
upstream: banks, credit card companies and regulators....

Amadeu, wearing his laywer and former European Commission's DG 
competition Policy staff hats....