[IAG-WHOIS conflicts] Article 29 Response to the updated EU Data Protection Regulations

[Carlton Samuels]

The Commissioners sent a letter to the three parties contemplating the
updated data protection regulations.  Among other matters, there's this:

 "......
*The definition of personal data should therefore take into account the
situation in which people can be “singled out” on the basis of identifiers
or other information and could subsequently be treated differently. This
definition should also take into account the recent CJEU rulings
considering why and to what extent IP addresses and other online
identifiers are as a general rule to be considered personal data." *

The Letter can be found here
<http://ec.europa.eu/justice/data-protection/article-29/documentation/other-document/files/2015/20150617_letter_from_the_art29_wp_on_trilogue_to_msjourova.pdf>
as well as an attachment to this message.

In an Appendix
<http://ec.europa.eu/justice/data-protection/article-29/documentation/other-document/files/2015/20150617_appendix_core_issues_plenary.pdf>
to
the letter, they outlined and pronounced on what they see as the core
issues; they endorsed the validity of Binding Corporate Rules as mechanisms
to manage cross border transfer of personal data, declined to support risk
factors as a measure to mitigate data controller's accountability, endorsed
MLATs as the gold standard for access to personal data by public
authorities as well as new powers for EDPBs to exact penalties.

When all is said and done, countries are busy carving out bits and pieces
that run counter to the ideals, all in furtherance of the 'national
security interests' as they see them.

-Carlton
==============================
Carlton A Samuels
Mobile: 876-818-1799
*Strategy, Planning, Governance, Assessment & Turnaround*
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