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

Carlton Samuels carlton.samuels at gmail.com
Wed Oct 31 18:00:19 UTC 2018

I'm at EDUCAUSE so cannot join right now.

So, we have evidence that even in EU jurisdictions there are different DP
regimes implemented in government and yes, by ccTLDs. We are not hearing a
claim of inconsistency with law and regulation.

We know that in the UK - reprising Brexit - the law allows and the ccTLD
exercises a definitional attribute distinguishing between legal and natural

In these instances there is a causal connection in these distinctions that
have a bearing on the collection and publication views of a WHOIS record.

I'm struggling to understand why the principle of distinguishing
registrants as discretely as possible merits a fight? Especially if what is
requested in collection is merely linkable data??


*Carlton A Samuels*

*Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround*

On Wed, Oct 31, 2018 at 12:32 PM Alan Greenberg <alan.greenberg at mcgill.ca>

> 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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