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The first draft of the EPDP Response is now uploaded. It is essentially the same as that presented on the CPWG call on 28 Nov 2018.<br>
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One point on which there was significant discussion on the call was whether we should support geographic differentiation - that is, only apply redaction if the geographic location of the registrar/registry and the registrant warrant it or allow contracted parties
ot redact for all registrations. When this was previously discussed, there was quite a divide between those who felt we should differentiate, and those who felt that a contracted party could decide whether to do it or not (ie a registrar, for instance) could
decide to treat all registrants as if they were in the EU, and similarly a registrar outside of the EU (with
<b>no</b> connection there) could also redact all data.<br>
<br>
One of the things that has changed is that the European Data Protection Board has recently issued a document making it clear that an organization with NO presence or processing in the EU, offering services through the web, could have EU-based customers and
not be subject to the GDPR - <b>IF they do not explicitly target EU customers. Simple availability of a website in the EU does not constitute targeting. That take a large number of contracted parties who many of us had thought would be subject to the GDPR
out of the game. See </b><a href="https://community.icann.org/download/attachments/99484375/edpb_guidelines_3_2018_territorial_scope_en.pdf?version=1&modificationDate=1544386236959&api=v2">Guidelines 3/2018 on the territorial scope of the GDPR</a>.<br>
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On the CPWG when the question as ask about supporting geographic differentiation (oe Registrars/Registries should only redact when GDPR requires it, the overwhelming number agree (via check marks or voiced comments). This position is reflected in answers 86
and 89.<br>
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Please add your comments on any of the replies to the wiki - <a href="https://community.icann.org/x/1wLuBQ" eudora="autourl">
https://community.icann.org/x/1wLuBQ</a>.<br>
<br>
Alan<br>
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