[Gnso-epdp-legal] Updated legal v. natural questions (Melina)

[Caitlin Tubergen]

Dear Legal Committee,

Apologies for the double email.

Please find the slightly adjusted version from Melina below:

Would you change or add anything else on your analysis under points 1, 2 and 3 if an additional step is introduced after distinguishing between natural and legal persons, as described in the 2-step approach below? In particular, could you please assess the level of risk (if any) of such approach:
a.           Step one,  allow self-identification of registrant as either natural and legal person. If natural, then full redaction of data remains in place, if legal go to step 2.
b.          Step 2,  Further distinguishing between data of legal persons which contain personal information and data which contain non-personal information. Publish only non-personal information.

Please advise on potential further steps that could be taken on how to safely implement such an approach to minimize liability for wrongful disclosure (if different than the steps described above).

Please review the edits from the above version and reply via the mailing list by COB Friday, 19 March if you have any proposed edits or concerns.

Best regards,

Berry, Marika, and Caitlin



From: Gnso-epdp-legal <gnso-epdp-legal-bounces at icann.org> on behalf of Caitlin Tubergen via Gnso-epdp-legal <gnso-epdp-legal at icann.org>
Reply-To: Caitlin Tubergen <caitlin.tubergen at icann.org>
Date: Thursday, March 18, 2021 at 9:05 AM
To: "gnso-epdp-legal at icann.org" <gnso-epdp-legal at icann.org>
Subject: [Gnso-epdp-legal] Updated legal v. natural questions (Melina)

Dear Legal Committee,

Thank you to Laureen for working with Melina to edit the highlighted questions in the attached document; as a reminder, the other questions in this document have already been submitted to Bird & Bird – please only review the highlighted questions. We have provided the questions below for ease of reference:

4.  Would you change or add anything else on your analysis under points 1, 2 and 3 if an additional step is introduced after distinguishing between natural and legal persons, as described in the 2-step approach below? In particular, could you please assess the level of risk (if any) of such approach:
a.           Step one,  allow self-identification of registrant as either natural and legal person. If natural, then full redaction of data remains in place, if legal go to step 2.
b.           Enable registrant to further confirm that its provided data contains only non-personal information.
c.           Step 2,  Further distinguishing between data of legal persons which contain personal information and data which contain non-personal information. Publish only non-personal information.

Please advise on potential further steps that could be taken on how to safely implement such an approach to minimize liability for wrongful disclosure (if different than the steps described above).

Please review Laureen and Melina’s edits and reply via the mailing list by COB Friday, 19 March if you have any proposed edits or concerns.

Best regards,

Berry, Caitlin, and Marika
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