[Gnso-epdp-legal] [Ext] Re: Legal Committee Adobe Room

[Caitlin Tubergen]

Hi Margie,

 

Ruth has a copy of the questions in the Initial Report, and the team discussed some clarifications during the small team meeting. 

 

Here are is what we captured regarding clarifications to the questions in the Initial Report:

 

1. Footnote 15 in the 15 July 2018 letter from the EDPB to ICANN provides:

 

“The notice requirements applicable to registrars described in the Temporary Specification (in particular at paragraph 7.1.3) do not clearly state that the provision of separate administrative and technical contact is voluntary rather than obligatory. Moreover, it should be ensured that the individual concerned is informed[.]”

 

With respect to the term “informed”, what would be appropriate notice, assuming the information is being held in a system where it is disclosed to specific categories of people/entities who meet certain established criteria?

 

2. If a registrar permits a registrant, at the time of domain name registration, to self-identify as a natural or legal person, does a registrant’s incorrect self-identification that results in the public display of personal data create liability under GDPR? If so, please advise, for each possible participant in the domain name registration process listed below, if that participant incurs liability.

· Registrar

· Reseller

· Registry Operator

· Backend service provider (for registrar and/or registry operator)?

 

Thank you.

 

Best regards,

 

Marika, Berry, and Caitlin

 

 

 

 

From: Margie Milam <margiemilam at fb.com>
Date: Friday, January 18, 2019 at 4:48 AM
To: Hadia El Miniawi <hadiaminiawi at yahoo.com>, "gnso-epdp-legal at icann.org" <gnso-epdp-legal at icann.org>, Stephanie Perrin <stephanie.perrin at mail.utoronto.ca>, Caitlin Tubergen <caitlin.tubergen at icann.org>
Subject: [Ext] Re: [Gnso-epdp-legal] Legal Committee Adobe Room

 

Can we resend the latest version of the questions?

 

From: Gnso-epdp-legal <gnso-epdp-legal-bounces at icann.org> on behalf of Hadia El Miniawi via Gnso-epdp-legal <gnso-epdp-legal at icann.org>
Reply-To: Hadia El Miniawi <hadiaminiawi at yahoo.com>
Date: Thursday, January 17, 2019 at 7:17 AM
To: "gnso-epdp-legal at icann.org" <gnso-epdp-legal at icann.org>, Stephanie Perrin <stephanie.perrin at mail.utoronto.ca>, Caitlin Tubergen <caitlin.tubergen at icann.org>
Subject: Re: [Gnso-epdp-legal] Legal Committee Adobe Room

 

Hi all,

 

Following on our meeting yesterday,  the discussion with regard to the first question led us to deviate from the main purpose of it. The question was originally brought up because we were discussing maintaining the tech and or admin fields and there was a concern raised in relation to the notification issue raised in the EDPB letter. Therefore I believe that we should stick to the main purpose and ask specific questions that refer directly to the admin and tech contacts. If in addition to that you would like to ask about third parties in general that is fine but we should also have separate specific questions that address the issue of the tech and admin contacts.  

 

 

Best

Hadia

 

On Wednesday, January 16, 2019, 12:45:39 PM EST, Caitlin Tubergen <caitlin.tubergen at icann.org> wrote: 

 

 

Please use the following link for Legal Committee Meeting: https://participate.icann.org/pls

 

 

 

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