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

[Ayden Férdeline]

Hi Rob,

Assuming the registrant is an individual, the right to erasure in GDPR is not absolute. Whether or not data must be deleted (or perhaps quarantined) is complex. What there will need to be, however, is a process in place to manage these requests in a consistent manner. Who will develop/own that process I do not know...

Best wishes,

Ayden Férdeline
[linkedin.com/in/ferdeline](http://www.linkedin.com/in/ferdeline)

> -------- Original Message --------
> Subject: Re: [gnso-rds-pdp-wg] ICANN Meetings/Conversations with Data Protection and Privacy Commissioners
> Local Time: 23 September 2017 4:23 AM
> UTC Time: 23 September 2017 03:23
> From: rob.golding at astutium.com
> To: gnso-rds-pdp-wg at icann.org
>
> 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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