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

Alan Greenberg alan.greenberg at mcgill.ca
Tue Oct 30 13:49:32 UTC 2018

We will certainly have to address similar legislation in other countries, but the problem is that it may vary country to country, with some less stringent than the EU and some more.  For the "more" case, that will almost certainly require country identification.


At 30/10/2018 07:21 AM, Vanda Etges wrote:
Considering several countries like in Latin America for instance are approving one by one its own law GDPR compliant I would bet on the universal , ignoring distinction related to place since in few years they will need to extend to all clients

Vanda Scartezini
Sent from my iPhone
Sorry for typos

On 30 Oct 2018, at 08:06, Tijani BEN JEMAA < tijani.benjemaa at topnet.tn<mailto:tijani.benjemaa at topnet.tn>> wrote:

I do understand the contracted parties who push back for at least 2 reasons:

  *   the mobility of registrants
  *   the complexity of managing 2 kind of treatment

I though it was said in the beginning that the contracted parties should remain free to apply universally or only for the European subjects. This is in my opinion the best choice.

Executive Director
Mediterranean Federation of Internet Associations (FMAI)
Phone: +216 98 330 114
          +216 52 385 114

Le 30 oct. 2018 à 02:32, Alan Greenberg <alan.greenberg at mcgill.ca<mailto:alan.greenberg at mcgill.ca> > a écrit :

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.

Alan<RySG revisions Small Team #2 Geographic - updated.pdf>_______________________________________________
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