[Gnso-epdp-team] Recommendation 1 Purpose 1 - RrSG Comments
Sarah Wyld
swyld at tucows.com
Fri Jan 25 21:14:01 UTC 2019
Hello All,
For Recommendation 1 Purpose 1, the RrSG has the following comments:
* Rename this to: Further Processing of Data.
* Within the ICANN context we want to process data collected for a
different purpose to be further processed for research purposes
o What is research within the ICANN context? And does it have
scientific purposes?
o Is the ARS Reporting system research, or as the name indicates a
reporting system that flags possible incorrect data? And is this
not already in scope of the GDPR?
o Art 89 and relevant recitals in scope due to whatever research
is within the ICANN context?
o Depending on the research do Art 17 and 21 apply?
* *In short with the above in mind, what does the WG think is research
and does it require processing of personal data?*
--
Sarah Wyld
Domains Product Team
Tucows
+1.416 535 0123 Ext. 1392
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