The AntiPhishing Working Group (APWG) in a letter to ICANN has expressed concern that the redaction of the WHOIS data as defined by GDPR for all domains is "over-prescriptive". APWG which is an international coalition of private industry, government and law-enforcement actors, says such a redaction of WHOIS data will "hinder legitimate anti-spam, anti-phishing, anti-malware and brand protection activities, particularly efforts to identify related domains that are under unified (e.g., cyber attacker's) control." Kevin Murphy reporting in Domain Incite says: "The hashing system may also be beneficial to interest groups such as trademark owners and law enforcement, which also look for registration patterns when tracking down abuse registrants. The proposal would create implementation headaches for registries and registrars — which would actually have to build the crypto into their systems — and compliance challenges for ICANN."
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