[registration-issues-wg] [CPWG] EPDP: Geographic distinction

Alan Greenberg alan.greenberg at mcgill.ca
Tue Oct 30 01:32:34 UTC 2018

GDPR is applicable to residents of the EU by companies resident there 
and worldwide.

One of the issues is whether contracted parties should be allowed or 
required to distinguish between those who are resident there and elsewhere.

There is agreement that such distinction should be allowed, but EPDP 
is divided on whether it should be required. The GAC/BC/IPC want to 
see the distinction made, and at least one very large contracted 
party does already make the distinction. Other contracted parties are 
pushing back VERY strongly saying that there is virtually no way that 
the can or are willing to make the distinction.

The current (confusing) state of the working document is attached.

Which side should ALAC come down on?

- Restrict application to those to whom GDPR applies?
- Apply universally ignoring residence?

As usual, quick replies requested.

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