[registration-issues-wg] [CPWG] EPDP Answer omissions?

Alan Greenberg alan.greenberg at mcgill.ca
Sun Jan 6 19:51:11 UTC 2019

There have been questions asked as to why we omitted replying to 
certain questions in the EPDP response (in particular Recs 13, 14 and 21).

This was not an error, but intentional. The Recs were in relation to 
Data Processing roles and responsibilities, the classification of who 
is the "controller" under GDPR, and what formal agreements need to be 
in place between the various contracted parties and ICANN. The answer 
is that we did not think that these issues had specific relevancy to 
Individual users nor did we have the legal expertise to contribute 
strong arguments.


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