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

[Volker Greimann]

I do not see why we need step 1 in the first place. The only relevant
information is whether the data contains personal information or not. The
differentiation between legal and natural is totally irrelevant to this.


*4.  Would you change or add anything else on your analysis under points 1,
2 and 3 if registrant is enabled to confirm that its provided data contains
only non-personal information. Disclose only data sets containing
non-personal information. *


*This version is quick and to the point of the core of the matter. Why
complicate things needlessly?*




-- 
Volker A. Greimann
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On Thu, Mar 18, 2021 at 3:03 PM Caitlin Tubergen via Gnso-epdp-legal <
gnso-epdp-legal at icann.org> wrote:

> 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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