[gnso-rds-pdp-wg] ICANN Meetings/Conversations with Data Protection and Privacy Commissioners

Rob Golding rob.golding at astutium.com
Sat Sep 23 03:23:34 UTC 2017


On 2017-09-23 03:06, Chuck wrote:
> 	* The GDPR is set to go into effect in May 2018.

The GDPR came into effect 20 days after it was published on the 5th May 
2016

Data Processors should be 18months into making they're compliant and 
have the appropriate policies/procedures in place before _enforcement_ 
of the regulations starts on May 2018

> 	* Therefore, it does not seem unreasonable for ICANN staff to be
> exploring ways to resolve this dilemma

I'm not sure there is a dilemma - the contract can't require you to 
break the law.

Certain aspects of the GDPR will be "interesting" to see how this PDP 
interprets such things as the right to erasure - does that mean RDS must 
somehow prohibit all forms of "copying" of the data - how exactly that 
can be handled if viewed by people with photographic memories, or 
someone taking an actual photograph with their James Bond matchbox spy 
camera ?

etc

Rob


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