[Gnso-epdp-team] Points of Order
Alan Greenberg
alan.greenberg at mcgill.ca
Wed Apr 14 23:35:53 UTC 2021
I would like to raise two points of order.
Although my preference is for the PDP to generate consensus policy on
the Legal/Natural issue, I understand that ultimately that may not be
possible. That being said:
1. There have been recent discussions that we should not be creating
advice on whether a registrant is a legal or natural person, but
rather whether the data items contain personal information. The
wording from the EPDP Charter is "Should Contracted Parties be
allowed or required to treat legal and natural persons differently,
and what mechanism is needed to ensure reliable determination of
status?" If there is a need to consider individual data items, that
is a secondary issue, but we need to stick to the charter terms.
2. The Key Metrics Considerations part of the EPDP Charter requires
the we ensure that we will have metrics to determine the success of
our recommendations. As such, if we decide that we will not issue
policy recommendation on the legal/natural issue, but rather only
guidance, we must also include a policy requirement that contracted
parties report on whether or not they are actually following the
guidance. If we do not do that, there is no way to measure our
ultimate success.
Alan
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