Hi Mike,

On 11/04/18 17:54, Mike Silber wrote:
> However I am still not certain that holding any of that information
> actually makes AfriNIC a controller in terms of the GDPR.

Article 4, paragraph 7 of the General Data Protection Regulations
defines the data controller as follows:

    ‘controller’ means the natural or legal person, public authority,
    agency or other body which, alone or jointly with others, determines
    the purposes and means of the processing of personal data; [...]

In my opinion, AfriNIC positions itself as a data controller by
collecting and processing personal data for a purpose (or several
purposes).

Regards,

Ish Sookun

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