[Gdd-gnso-ppsai-impl] PP IRT status update; no meeting Tuesday

[Sara Bockey]

Hi Amy,

I’m a little unclear as to how we intend the Privacy/Proxy Accreditation Agreement to dictate the terms for data processing, as this is something that will need to be agreed to between the Registrar and the Privacy/Proxy Provider, unless the intent is to create a standard set of terms that are included as a model, but capable of being modified or supplemented by the Registrar?  If so, then perhaps this should be handled similar to that of the recent RRA Amendment, which adds appropriate data processing terms to the RAA (via the form and process outlined here https://www.icann.org/en/system/files/files/rra-amendment-terms-temp-spec-02jul18-en.pdf).  It would differ in that these terms could be directly incorporated into the P/P Accreditation Agreement, rather than via an amendment as in the case of the previously executed RAAs, and the form and substance would need to be modified for these particular purposes, but the concept of “model clauses” might be viable.

In any event, we do not believe use of Section 4 of the Temp Specification is adequate or appropriate for these purposes.

Sara

sara bockey
sr. policy manager | GoDaddy™
sbockey at godaddy.com<mailto:sbockey at godaddy.com>  480-366-3616
skype: sbockey

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From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces at icann.org> on behalf of Amy Bivins <amy.bivins at icann.org>
Reply-To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Date: Thursday, July 12, 2018 at 12:13 PM
To: "gdd-gnso-ppsai-impl at icann.org" <gdd-gnso-ppsai-impl at icann.org>
Subject: [Gdd-gnso-ppsai-impl] PP IRT status update; no meeting Tuesday

Dear Colleagues,

We will not have a PP IRT meeting on Tuesday, 17 July. Our next meeting is scheduled for Tuesday, 24 July.

The Legal review of the current PPAA draft is not yet complete. However, I do have an update on the GDPR-related work.

We believe that we will likely need to add data processing provisions in the PP materials—potentially in the policy document. We are planning to begin drafting this, for discussion with you, using Section 4 of the Temporary Specification<https://www.icann.org/resources/pages/gtld-registration-data-specs-en/#4> as a model for adaptation. If you have other ideas or recommendations for this initial drafting exercise, please let us know. We can discuss this at our next meeting. A data processing addendum may also be needed for the PPAA.

In addition, we are also considering how to address data processing in data escrow agreements. I should have more to share on that with you by our next meeting.

Best,
Amy

Amy E. Bivins
Registrar Services and Engagement Senior Manager
Registrar Services and Industry Relations
Internet Corporation for Assigned Names and Numbers (ICANN)
Direct: +1 (202) 249-7551
Fax:  +1 (202) 789-0104
Email: amy.bivins at icann.org<mailto:amy.bivins at icann.org>
www.icann.org<http://www.icann.org>

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