At the start of the year, SIDN organised a webinar on the implications of the GDPR for domain name registration. Participants were asked whether they had set up a data processing register, as required under the new legislation. And no fewer than 66 per cent of the registrars responded by saying that they hadn't yet set one up. A broadly similar picture emerged when the RA surveyed its members to find out how many were GDPR-compliant. From the survey feedback, it was also clear that registrars would welcome support bringing their activities into line with the directive. The RA and SIDN therefore linked up with the ICTRecht legal consultancy to create the Privacy Portal, which opened for business on 27 September 2018. The Portal is intended to advise registrars on recording and protecting sensitive information and other privacy-related issues. "The Privacy Portal offers registrars free guidance on all aspects of privacy management," explains Sebastiaan. "You can get answers to legal questions, or help with data processing agreements and other documents." Dozens of registrars have already turned to the Portal for assistance.
How does the Portal work?
When you first contact the Privacy Portal, you'll be asked a few general questions. Your answers are used to build up a profile, after which you can create an account for a customised environment. Through the account, tailored advice is made available and appropriate measures are suggested. Facilities are also available for organising your enquiries and documents. "The intake privacy scan provides an immediate impression of what you've got under control and what still needs attention," adds Margreth.
The Portal also features a tool that can be used to set up and maintain a data processing register, another of the GDPR's new requirements. There's a privacy statement generator as well, and a utility for checking the adequacy of your technical data protection measures. Another feature of the Privacy Portal is its data breach registration functionality, which you can use to comply with the GDPR's requirement that details of all breaches must be recorded. Finally, there's a tool for generating appropriate data processing agreements to regulate your relationships with any data processors that handle data on your behalf. In other words, the Privacy Portal offers all kinds of assistance with GDPR-compliance.
"Registrars process a great deal of personal data and cooperate with other actors, including suppliers and partners. They collect registrants' personal details, for example, and forward the information to us on the registrants' behalf. That's how a domain name is registered. Naturally, it's primarily the registrars' responsibility to make sure that their data processing complies with the law. However, it's also very much in our interests to see that registration data is processed and exchanged securely," continues Sebastiaan. As Margreth points out, registrars have a lot on their plates, even without the GDPR. "Their core business is domain name registration, and compliance with the many rules and regulations that apply to the industry sometimes gets sidelined. So the Portal has been created with the aim of relieving some of the burden and making compliance easier for registrars. For any registrar who sees GDPR compliance as a dauntingly high mountain, the Privacy Portal will act like a Sherpa. You've still got to get up the mountain yourself, but the Portal is there to shoulder some of the load."
Part of something bigger
The Privacy Portal is just one of the ways that the RA and SIDN are working together to support and invest in the registrar community. It is a spin-off from the Legal Help Desk opened earlier in the year. Via the Help Desk, all 1250 or so .nl registrars can get free legal advice regarding issues involving contracts, ICT, terms and conditions and the like. Questions are simply submitted to the Help Desk using a standard form. Another product of cooperation between SIDN and the RA is the SIDN Academy. Sebastiaan: "So far, we've run three SIDN Academy sessions for registrars. The one-day sessions are intended for sharing knowledge on particular topics. The first round of sessions was devoted to e-mail security, for example."
Margreth and Sebastiaan have no preconceptions about how the Help Desk and Portal should develop from here. Both are really still pilot services. "We'll evaluate the situation after twelve months," says Margreth. "The future direction of the projects will depend on how registrars use these facilities in practice. A positive response and high levels of use will encourage us to continue and extend the services."
Providing the support you need
Registrars can therefore count on SIDN and the RA for various forms of help with keeping data secure. That support is very important, because GDPR compliance is an ongoing requirement. The Directive's introduction may have been back in the spring, but registrars need to keep their compliance under review and address any issues that they haven't yet tackled. Interested to know more about what the Privacy Portal and Legal Help Desk can mean for you? Visit the on-line Portal or come to SIDN Connect on 29 November. At SIDN Connect, you'll be able to ask (legal) questions and do an on-the-spot privacy scan at the Privacy Portal stand.