Firstly – AfriNIC does hold data on EU residents – that is without question – I 
know of a couple of cases of EU residents with their data held by AfriNIC 
without even thinking of it.
Secondly – irrespective of if they are signatories or not – if AfriNIC chooses 
to do any business with RIPE for example, they are doing business with an EU 
entity and can be prevented from doing so if they don’t comply is my 

Irrespective of this – the AfriNIC board if they believe they do not need to 
comply in any way shape or form – needs to state that to this community and to 
its members and give reasons as to why not – at that point – the affected 
members can then make an informed decision as to their course of action should 
they choose one. But – AfriNIC still has an obligation to inform its community 
as to its standing in this regard and do so before the legislation becomes 

Please note clause 3.4.vii of the bylaws:

(vii) to disseminate among its members information on all matters affecting the 
Company and its members and to provide for and be a central channel of 
communication for the members of the Company and generally for the furtherance 
and promotion of their interests;


From: Owen DeLong [mailto:o...@delong.com]
Sent: 11 April 2018 09:08
To: Andrew Alston <andrew.als...@liquidtelecom.com>
Cc: General <community-discuss@afrinic.net>; AFRINIC Board of Directors' List 
Subject: Re: [Community-Discuss] AFRINIC and the GDPR
Importance: High

On Apr 10, 2018, at 22:42 , Andrew Alston 
<andrew.als...@liquidtelecom.com<mailto:andrew.als...@liquidtelecom.com>> wrote:

Hi AfriNIC Board,

Can this board please *urgently* inform this community as to what preparations 
they have made as regards to compliance with the General Data Protection 
Regulations passed by the European Commision and the board will be in a 
position to give this community a full and complete report as to their GDPR 
compliance status and what will be changing before the 25th of May to ensure 
that when the GDPR comes into force AfriNIC is compliant.

Is Mauritius signatory to some treaty making them subject to GDPR?

Considering that the regulation comes into force on the 25th of May 2018 – and 
AfriNIC is 100% holding data of EU Citizens, which makes them subject to the 
regulations irrespective of the fact that they are domiciled in Mauritius – 
this is an urgent and critical issue.  It has direct impact on the whois 
database, abuse contact information, handling of data submitted during 
application process and potentially even the proposed review policy, just to 
name a few things that I can think of off the top of my head – and cannot be 
ignored.  I would in fact have liked to have seen discussions by the board in 
the minutes that have been published about the GDPR long before now – 
considering the impact – but failing that – the question is now being asked.

It’s not about EU Citizens. It’s about EU Residents. (Common misconception 
about GDPR).

Further, unless your in a silly country that was dumb enough to sign a treaty 
extending EU’s legal reach into your sovereignty, such as the stupid congress 
of the united States, then you can offer the EU a nice big Italian sign 
language gesture regarding their GDPR and continue on with business as usual.


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