Dynadotโs practice of directly requesting the upload of a government-issued ID and a selfie video without using a certified third-party KYC or identity verification provider raises serious additional GDPR compliance concerns.
Most companies that require identity verification rely on established third-party KYC processors (e.g. Onfido, Veriff, SumSub, Jumio), which operate under strict GDPR-compliant frameworks, encryption standards, and data minimization protocols. These services typically return only a verification token (e.g. โverified = trueโ) to the controller, ensuring that sensitive personal data such as ID documents and biometric images are not permanently stored or processed by the requesting company.
Dynadotโs direct collection and storage of these materials make it the sole data controller of highly sensitive information, including government identification numbers and biometric data. This approach substantially increases the risk of noncompliance with several GDPR provisions, specifically:
Article 5(1)(c) (data minimization), since the company holds more data than necessary for account verification;
Article 32 (security of processing), as the company must demonstrate robust, documented technical and organizational safeguards equivalent to those of regulated KYC processors; and
Articles 44-49 (cross-border data transfers), given that Dynadot is based in the United States and appears to lack any declared transfer mechanism such as Standard Contractual Clauses (SCCs) or equivalent safeguards.
This handling method represents an unnecessary privacy risk, both in terms of data breach exposure and noncompliance with the GDPRโs proportionality principle, especially considering that my identity could easily be verified through existing account credentials, payment records, or contact confirmation.
Even though I still consider id verification excessive in our situation, I would be ok doing it through a reputable 3rd party KYC provider. Alternatively, let me try entering the PIN or security question one more time.
We all remember the epik data breach and the personal data that were leaked then. I don't want this to happen with my id.