[Gnso-epdp-team] Recommendation 1 Purpose 1 - RrSG Comments

[Alan Greenberg]

As Milton suggested and I supported, the ARS is a tool to monitor to what extent contact data is accurate. In essence it is a compliance-related audit and reasonably fits in the compliance purpose. It is not currently executed by the Contractual Compliance department, but I fail to see the relevance of that from a GDPR purpose point of view.

Alan

At 25/01/2019 04:14 PM, Sarah Wyld wrote:
From: Sarah Wyld <swyld at tucows.com>
To: gnso-epdp-team at icann.org
Subject: Recommendation 1 Purpose 1 - RrSG Comments

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
     *   What is research within the ICANN context? And does it have scientific purposes?
     *   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?
     *   Art 89 and relevant recitals in scope due to whatever research is within the ICANN context?
     *   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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