[Gnso-epdp-legal] Proposed agenda - EPDP Phase 2 Legal Committee Meeting #4

[Hadia El Miniawi]

Hi Tara,

Thanks for your detailed email and apologies for the late response I am currently at the airport waiting for a connecting flight. There is clearly an overlap between the questions though each one is addressing a specific concern. In relation to the automation of the decision making I now find that it is best to have it as a standalone question. Article 22 of the GDPR addresses the issue of having decisions based solely on automated decisions, it is important to the work of this group to know what are the conditions under which automated decision making will be possible. The concept of automating the decision making is not necessarily related to whether we have an accreditation system or not or whether we would like to automate the disclosure or not. Therefore, my suggestion to the group is to add a standalone question that addresses solely the concept of automating the decision making in relation to the disclosure of the data and regardless of whether the disclosure is under 6(1)f or another article.

Best
Hadia

Hadia Elminiawi 
Director, DNS Entrepreneurship Center
National Telecom Regulatory Authority of Egypt

> On Aug 20, 2019, at 4:36 PM, Tara Whalen <tjwhalen at gmail.com> wrote:
> 
> Can a data controller rely on advice or assertions that come from a qualified and trusted third party in order to help satisfy 6(f)’s balancing test?  If it is possible, then what are the considerations?  What if any legal agreements need to be place? If this is not possible