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

[Jonathan Zuck]

Of course, as a practical matter with the contracted parties trying to limit liability and the NCSG trying to limit everything, this restriction isn't going to happen. We nee to huddle and figure out where to really fight the good fight.

On 10/30/18, 11:39 AM, "GTLD-WG on behalf of Carlton Samuels" <gtld-wg-bounces at atlarge-lists.icann.org on behalf of carlton.samuels at gmail.com> wrote:

    Restrict.   But the [processing] principle at issue is really about
    granularity of data; granularity enables pointed decision-making.
    
    Multiple DP/P regimes are emerging, all of them sharing principles but
    often because of application makes for small to significant differences. In
    fact even in EU member states there are differences.
    
    Encourage granularity.
    
    -Carlton
    
    ==============================
    *Carlton A Samuels*
    
    *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround*
    =============================
    
    
    On Mon, Oct 29, 2018 at 8:33 PM Alan Greenberg <alan.greenberg at mcgill.ca>
    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.
    >
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