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

[Carlton Samuels]

It's a good thing I read top down before my response. Because I would have
to disagree with you about the matter of who is a controller or processor
in the ICANN context and the importance to users.

That question goes to the heart of this entire argument but most
importantly, it establishes agency.

As such, those matters are of supreme importance to users.

And while I disagree with the posture that a legal question is beyond the
ordinary ability of At-Large interests to assess and apply a commonsensical
interpretation,  I'm glad you corrected.

 Carlton

On Sun, 6 Jan 2019, 4:08 pm Alan Greenberg <alan.greenberg at mcgill.ca wrote:

> 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.
>
> Alan
>
> 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
> >
> >Holly
> >
> > > 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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