[Gnso-epdp-team] redacted data

Thomas Rickert epdp at gdpr.ninja
Thu Aug 23 13:23:03 UTC 2018

We know that the organization field has the same information as the registrant field. Therefore, a logical consequence should be a redaction requirement for the org field, too.

However, as I mentioned in the chat during the last call: The problem could go away if the EDPB gave its blessing to using the registrant’s self-identification as a compliant solution for distinguishing between natural and legal persons.


> Am 23.08.2018 um 15:19 schrieb Mueller, Milton L <milton at gatech.edu>:
> Thanks, Thomas. So you want possibly more redaction.  I will add that to the list.
>   <>
> From: Thomas Rickert [mailto:epdp at gdpr.ninja <mailto:epdp at gdpr.ninja>] 
> Sent: Thursday, August 23, 2018 9:05 AM
> To: Mueller, Milton L <milton at gatech.edu <mailto:milton at gatech.edu>>
> Cc: Thomas Rickert <epdp at gdpr.ninja <mailto:epdp at gdpr.ninja>>; gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>
> Subject: Re: [Gnso-epdp-team] redacted data
> Milton,
> Let me qualify the ISPCP input: Not redacting the „Organization“ field is problematic. 
> Best,
> Thomas
> Am 23.08.2018 um 15:00 schrieb Mueller, Milton L <milton at gatech.edu <mailto:milton at gatech.edu>>:
> I have raised this point several times and I see it being avoided.
> The redacted data elements are one of the most important aspects of the temp spec.
> It is imperative that this group identify specifically which redactions we agree with and which ones certain stakeholders don’t agree with. This should be very simple to do.
> I would propose that we add to the Triage report a simple list of each redacted data element, and then list who agrees and disagrees with its redaction. Those opposing a redaction must explain why they think publishing that data is consistent with GDPR and other privacy laws that may apply.
> My understanding is that the NCSG, RySG, RrSG, ALAC and ISPC all are ok with the current set of redactions under the temp spec.
> It is therefore incumbent upon the BC, IPC, and GAC to specify which data elements they think should be published and which they are ok with redacting.
> Again, this seems like a very simple thing to do and as a form of “triage” would be most helpful for the group’s progress
> Dr. Milton L. Mueller
> Professor, School of Public Policy
> Georgia Institute of Technology
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