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

Alan Greenberg alan.greenberg at mcgill.ca
Sun Jan 6 21:08:28 UTC 2019

On rereading my reply, I find I may not have been sufficiently 
precise. The issue of who the controller is or who the controllers 
are is actually of great importance to users, as it ultimately 
implies who has liability under GDPR and therefore who may or may not 
take risks {and therefore how "open" the RDS ends up). But it is the 
answer that has implications. Although I (and we) may have our "wish 
list" as to how we want it to come out, we do not have a lot to add 
to the deliberations.


At 06/01/2019 03:46 PM, Holly Raiche wrote:
>Thanks Alan
>When I read the questions, I was very unsure as to what I would 
>thing, but more importantly, if it is an issue for users.
>This confirms my thoughts so thanks for the explanation
> > On Jan 7, 2019, at 6:51 AM, Alan Greenberg 
> <alan.greenberg at mcgill.ca> wrote:
> >
> > 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.
> >
> > Alan
> >
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