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

Alan Greenberg alan.greenberg at mcgill.ca
Wed Oct 31 17:32:28 UTC 2018


At the moment we are quite divided on this issue.  If you cannot be 
on the CPWG call in 2 1/2 hours, please comment here. We need to 
report back to the EPDP on Thursday.

Alan

At 29/10/2018 09:32 PM, Alan Greenberg wrote:
>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
>
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