[Gnso-epdp-legal] [Gnso-epdp-team] Legal Advice Received

[Kurt Pritz]

Hi Ruth and Gabe: 

Please note below the comment from one of our team members regarding your memorandum on the handling of “City Name” as registration data. Let me know if you have questions or wish to make a change to the memo as a result of this input. 

[Thanks Theo]

Best regards,

Kurt


> On Feb 17, 2019, at 1:44 AM, Theo Geurts <gtheo at xs4all.nl> wrote:
> 
> Hi Kurt,
> 
> Thank you for distributing these. There is however an error in the last paragraph I think regarding the city field (3.18). Afnic and DNS BE (.FR and .BE) show no information of the natural person.
> 
> Most likely B&B got confused by the Onsite contacts that are being displayed, usually the hosting company, but these contacts are not registrants. 
> Example DNS BE:
> https://www.dnsbelgium.be/en/whois/info/123camion.be/details <https://www.dnsbelgium.be/en/whois/info/123camion.be/details>
> 
> For .FR you can see the WHOIS output as attached.
> 
> I think it is essential that such information is corrected to avoid assumptions by the EPDP that are incorrect and fuel further unwarranted discussion.
> If B&B needs assistance, they can contact me. 
> Best regards, 
> Theo Geurts    CIPP/E
> 
> 
> 
> 
> On 16-2-2019 22:31, Kurt Pritz wrote:
>> Hi Everyone: 
>> 
>> I have attached the two latest legal memoranda from Bird & Bird that the EPDP Legal Team has decided to pass on to the full team without comment. 
>> 
>> The two memoranda answer our questions about: 
>> Data Accuracy requirements, and
>> City name redaction / publication
>> 
>> I will take the liberty of noting that the "City Name” memo identifies that data element as personal data and then indicates that additional research is required to  determine if there is a legal basis for its publication. To me, this fits well with the current recommendation to redact the city name field pending result of additional; independent legal input. Currently, the report reflects the divergence of opinion on this recommendation. 
>> 
>> We are authorizing Bird & Bird to complete the research. We are currently waiting for an answer regarding geographical aspects. 
>> 
>> Any questions you have can be posed to the EPDP Legal Team or can also be forwarded to Bird and Bird. 
>> 
>> Best regards,
>> 
>> Kurt
>> 
>> 
>> 
>> 
>> 
>> 
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