[Gnso-ppsai-pdp-wg] Section III-C-(5)

Stephanie Perrin stephanie.perrin at mail.utoronto.ca
Tue Apr 14 16:17:03 UTC 2015

PII and this definition relates to individuals.  If the proxy 
registration is for a battered women's shelter, the address and phone 
number do not relate to an individual or at least do not lead to the 
identification of an individual.  I think using PII (which is different 
from PI, and not what is usually found in data protection law) leads us 
into waters that we dont need to enter.  We must remember that proxy 
services are used for groups, even companies.
Stephanie P

On 2015-04-14 12:03, Kiran Malancharuvil wrote:
> Hi Kathy,
> How does Terri’s language exclude those groups?
> Thanks,
> Kiran
> *From:*gnso-ppsai-pdp-wg-bounces at icann.org 
> [mailto:gnso-ppsai-pdp-wg-bounces at icann.org] *On Behalf Of *Kathy Kleiman
> *Sent:* Tuesday, April 14, 2015 9:01 AM
> *To:* gnso-ppsai-pdp-wg at icann.org
> *Subject:* Re: [Gnso-ppsai-pdp-wg] Section III-C-(5)
> Terry,
> I much prefer the original language since we are also working with the 
> privacy and speech protections also of political groups, battered 
> women's shelters, minority religious groups, Mom- and home-based small 
> businesses, etc. -- the wide array of legitimate groups, organizations 
> and businesses that use proxy/privacy providers.
> Best,
> Kathy
> :
>     Perhaps I am over-simplifying, but since agreement has not been
>     reached on the current language, and III-C-(3) actually gives the
>     provider quite a bit of lee-way to decide against disclosure, I
>     propose the following:
>     the Provider has found, specific information, facts and/or
>     circumstances that reveal the Requestor's trademark or copyright
>     complaint is a pretextual means of obtaining the Customer's
>     contact details solely for the purpose of contravening the
>     Customer's personally identifiable information.
>     1.*Personally identifiable information* (PII) is any data that
>     could potentially *identify* a specific individual. Any
>     *information* that can be used to distinguish one person from
>     another and can be used for de-anonymizing anonymous data can be
>     considered PII.
>     -- 
>     /Terri Stumme/
>     /Intellligence Analyst/
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