[gnso-rds-pdp-wg] Questions for Data Commissioners
Lisa Phifer
lisa at corecom.com
Mon Mar 6 23:26:00 UTC 2017
Regarding Q4:
The phrase "interact with the General Data Protection Regulation" was
supposed to be deleted from Q4; strike this phrase and I believe the
sentence reads as intended.
Q4 is indeed (as I understand it) intended to refer to registrars in
their capacity as service providers - for example, when a registrar
serves as a technical contact for a domain name. The question asks
whether that EU directive requirement on service providers would also
apply to registrars.
At 04:15 PM 3/6/2017, Gomes, Chuck wrote:
>Thanks for the quick feedback Steve. I encourage Lisa and Susan to
>respond but also inserted some responses of my own.
>
>
>
>Chuck
>
>
>
>From: gnso-rds-pdp-wg-bounces at icann.org
>[mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of Metalitz, Steven
>Sent: Monday, March 06, 2017 5:38 PM
>To: 'Lisa Phifer' <lisa at corecom.com>; RDS PDP WG <gnso-rds-pdp-wg at icann.org>
>Subject: [EXTERNAL] Re: [gnso-rds-pdp-wg] Questions for Data Commissioners
>
>
>
>Thanks Lisa. A few quick reactions:
>
>
>
>(1) As several members of the WG have repeatedly reminded us in
>this and other ICANN contexts, some/many/most national data
>protection authorities within the EU do not/will not/would rather
>not render advisory opinions. I understand that in fact there will
>be few if any participants in either of these sessions whose job is
>actually to enforce a specific national data protection law. Even
>so, questions asking for legal conclusions about violation of data
>protection laws (or of the GDPR, which has not yet come into force)
>in specific circumstances may not be the most constructive way to
>proceed. I especially marked the last sentence of Q.3 as a good
>candidate for deletion.
>
>[Gomes, Chuck] Am I correct that you are suggesting that just the
>last question in Q.3 be deleted, i.e., "If so, would entities that
>collect and process this data be considered in violation of the
>Directive and the GDPR?" Regardless, please be ready to repeat this
>suggestion in our WG call tomorrow so we can see if the WG supports
>the deletion.
>
>(2) The first sentence of Q. 4 seems a bit garbled. In the second
>and third sentences, should the references to "registrars" be
>changed to "registrants"? (I did not know there was any issue to
>requiring registrars to make their contact information publicly
>available, though not necessarily in the RDS itself.)
>
>[Gomes, Chuck] I will let Susan & Lisa respond to this, hopefully
>before the WG call so that any edits made can be reviewed by the WG
>in our meeting.
>
>(3) Obviously there are more questions here than are likely to be
>addressed in either the Monday or Wednesday sessions so will there
>be any effort to prioritize them?
>
>[Gomes, Chuck] They fully realize that there are likely more
>questions than can be covered, especially if their answers are
>lengthy. My hope is that some of the questions will be discussed in
>the cross community session on Monday and that we can then just
>discuss the remaining questions on Wednesday. Even then, there may
>be too many so if you have any suggestions regarding priority please
>communicate them. I will let Susan & Lisa respond regarding whether
>they discussed priorities.
>
>
>
>Thanks and I hope these thoughts are still timely.
>
>
>
>Steve Metalitz
>
>
>
>Steven J. Metalitz | Partner, through his professional corporation
>
>T: 202.355.7902 | met at msk.com
>
>Mitchell Silberberg & Knupp LLP | www.msk.com
>
>1818 N Street NW, 8th Floor, Washington, DC 20036
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>From: gnso-rds-pdp-wg-bounces at icann.org
>[mailto:gnso-rds-pdp-wg-bounces at icann.org] On Behalf Of Lisa Phifer
>Sent: Monday, March 06, 2017 4:36 PM
>To: RDS PDP WG
>Subject: [gnso-rds-pdp-wg] Questions for Data Commissioners
>
>
>
>Dear all,
>
>A proposed final version of this WG's questions for data
>commissioners is attached and also posted on our wiki:
>
>* RDSPDP-QuestionsForDataCommissioners-v8clean.pdf and
>* RDSPDP-QuestionsForDataCommissioners-v8markup.docx
>
>Thanks to all who contributed questions and feedback to this list of
>questions. Please refer to the v8markup document to see how feedback
>was incorporated to produce the v8clean PDF.
>
>Once finalized during this week's WG call, a clean final list will
>be transmitted by Chuck to the moderator of the cross-community session:
>
> Monday 13 March 3:15-4:45pm CET (http://sched.co/9nnl)
>
>That list will also be provided to invited speakers for our
>Wednesday F2F session:
>
> Wednesday 15 March 1:45-3:00pm CET (http://sched.co/9npc)
>
>Best regards,
>Lisa
>
>
>
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