[gnso-rds-pdp-wg] Hamilton memo Part II

[Maxim Alzoba]

Hell all

I think text is quite blurry 

those bits might mean that the answers relevant for non-EU companies should not be expected 
(other than obey to EU law, even outside of EU):

2.15.2  Where data is processed outside of the EU (or if non-EU legislation would have extraterritorial reach), other data protection laws than European laws may apply. This is however outside the scope of our assessment and has not been reviewed by us.
and 

2.12.2  In order for a public interest to exist according to the GDPR, such interest needs to be laid down in either EU law or EU member state national law. 

though some useful items could be in part 3 (see 2.6.1) 



Sincerely Yours,

Maxim Alzoba
Special projects manager,
International Relations Department,
FAITID

m. +7 916 6761580(+whatsapp)
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> On Dec 19, 2017, at 03:01, Rubens Kuhl <rubensk at nic.br> wrote:
> 
> 
> 
>> On 18 Dec 2017, at 20:03, Michael Palage <michael at palage.com <mailto:michael at palage.com>> wrote:
>> 
>> Hello All,
>>  
>> More interesting reading, https://www.icann.org/en/system/files/files/gdpr-memorandum-part2-18dec17-en.pdf <https://www.icann.org/en/system/files/files/gdpr-memorandum-part2-18dec17-en.pdf>
> 
> Spoilers: like most movie trilogies, the more interesting stuff is coming in episode 3. But I found very interesting from this part is that GDPR applies to personal data regardless of the data subject being from EU or at EU. So an American citizen that feels damaged by an American registrar or registry could possibly have a GDPR cause of action because that contracted party also serves the EU. 
> 
> 
> 
> 
> Rubens
> 
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