[registration-issues-wg] [CPWG] DRAFT ALAC EPDP Advice

Bastiaan Goslings bastiaan.goslings at ams-ix.net
Sun Apr 7 06:02:34 UTC 2019

Hi Alan,

> On 5 Apr 2019, at 21:31, Alan Greenberg <alan.greenberg at mcgill.ca> wrote:
> Bastiaan, let me understand. What we are asking
> for is an opportunity for the EPDP to have a
> discussion weighing the pros and cons  - the
> balancing consideration called for under GDPR in
> deciding what data needs to be redacted.

The way I read the draft advise we are arguing for a lot more.

> So you are against the EPDP using the balance
> test prescribed by GDPR - something that was not done during Phase 1?

I’m not sure where you got that from, me supposedly being 'against the EPDP using the balance test prescribed by GDPR’. Let me reiterate myself:


I think I am pretty clear there: while I might disagree with you and others on the substance of the topic, if it was agreed up, based on 'the recollection of the ALAC and SSAC as well as the EPDP Chair’, that the (non-) necessity of geo distinction of registrants would be further discussed and decided on in phase 2, then I will most certainly support us reminding the board of that. But, again, that is not (only) what the draft advice is arguing for IMO.


> At 04/04/2019 04:06 AM, Bastiaan Goslings wrote:
>> Thanks a lot, Alan - your and Hadia’s efforts are much appreciated
>> (I was not on yesterday’s CPWG call so do not know how this was discussed)
>> It might not come as a surprise, but I do not
>> agree with the advice on ‘Geographic
>> Differentiation’. Both when it comes to the
>> framing/introduction as well as the conclusion.
>> I do not have time to elaborate on this know,
>> but happy to do so later - in the meantime see my previous comments.
>> I can agree with the 'Thick WHOIS’ concerns -
>> the part on 'Legal/Natural Person
>> Differentiation' seems redundant to me though,
>> this is already covered by rec#17: 'The EPDP
>> Team will determine and resolve the Legal vs. Natural issue in Phase 2’
>> cheers
>> Bastiaan
>> ***  Please note that this communication is
>> confidential, legally privileged, and subject to
>> a disclaimer: https://www.ams-ix.net/ams/email-disclaimer ***
>>> On 3 Apr 2019, at 15:59, Alan Greenberg <alan.greenberg at mcgill.ca> wrote:
>>> Please find attached a draft of the ALAC
>> Advice to the Board related to the EPDP.
>>> Note that the highlighting (inadvertantly
>> missing in the third case) gives two alternative pheasings to be discussed.
>>> Hadia has reviewed it and supports it.
>>> Alan
>>> --
>>> Sent from my mobile. Please excuse brevity and typos.
>>> <Advice-DRAFT-v01.docx>_______________________________________________
>>> CPWG mailing list
>>> CPWG at icann.org
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