[Gnso-epdp-team] Fwd: Re: draft EDPB

Wed Dec 5 10:59:32 UTC 2018

Dear Stephanie,

Thank you and all who have contributed to the  EDPB draft letter. However I do not agree with the statement in the first paragraph that says

" ICANN is a global non-governmental non-profit organization responsible for ensuring the stable and secure operation  of the Internet's system of unique identifiers, i.e., domain names and IP addresses."

The above statement attempts to define ICANN's mission - which is indeed out of our scope-  and strongly contradicts with what ICANN made note of in its letter of May 5 2018 to the EDPB and contradicts with the letter sent on July 5 from EDPB to Goran Marby in which the EDPB acknowledges that ICANN's mandate goes beyond ensuring the stable and secure operation  of the Internet's system of unique identifier. To remind you the letter of July 5  from EDPB said

" in its letter of 10 may 2018, ICANN makes several references to ICANN's Bylaws to underline that ICANN's mission with respect to domain names is not limited to ensuring the stable and secure operation of the internet unique identifiers system (technical stability). The EDPB has taken note of ICANN's Bylaws, which require ICANN, in carrying out its mandate ..."

I also do not agree with the statement in the draft letter that says " the ICANN Board adopted a Temporary Specification for gTLD Registration Data ("Temporary Specification"), which is intended to bring the domain name ecosystem into GDPR compliance"
The aforementioned intention of the temporary specification is too broad, the temporary specification is intended to ensure that the  Personal Data that is Processed by certain participants in the gTLD domain name ecosystem is in compliance with the GDPR, we are certainly not working on the whole domain name ecosystem nor is it within our mandate.

Finally I can see that the letter is mainly noting to the EDPB that the team has an initial report  that is published for public comment, and  it encourages the EDPB to provide feedback or comments in this regard. I am not sure about the outcome of such a letter, however if this is what you all  agree on I am fine with that.

Kindest Regards
Hadia

From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] On Behalf Of Stephanie Perrin
Sent: Tuesday, December 04, 2018 4:52 PM
To: gnso-epdp-team at icann.org
Subject: [Gnso-epdp-team] Fwd: Re: draft EDPB

 I am resending this letter for those who missed it, renaming as draft EDPB letter.

Stephanie

-------- Forwarded Message --------
Subject:

Re: [Gnso-epdp-team] Recordings, Attendance & AC chat from the GNSO Temp Spec gTLD RD EPDP Small Roles & Responsibilities team held on Thursday, 29 November 2018 at 18:00 and 21:00 UTC

Date:

Thu, 29 Nov 2018 22:45:29 -0500

From:

Stephanie Perrin <stephanie.perrin at mail.utoronto.ca><mailto:stephanie.perrin at mail.utoronto.ca>

To:

gnso-epdp-team at icann.org<mailto:gnso-epdp-team at icann.org>

And attached is the abbreviated version of the draft letter which I promised in the first meeting today.  I am very grateful to Kristina Rosette for her comments; we have it almost shrunk down to one page (if you like it, you can simply drop the font one point and we will be there :-))

Stephanie Perrin
On 2018-11-29 20:57, Terri Agnew wrote:
Dear all,

Please find the attendance and AC chat attached to this email. The MP3 and AC recording below from the two Small Teams to discuss the letter to the EDPB call held on Thursday, 29 November 2018 at 18:00 and 21:00 UTC.

These have also been posted on the agenda wiki page:  https://community.icann.org/x/bQbuBQ

First call MP3: https://audio.icann.org/gnso/gnso-epdp-small-call-1-29nov18-en.mp3

Second call MP3: https://audio.icann.org/gnso/gnso-epdp-small-call-2-29nov18-en.mp3

First call AC Recording:  https://participate.icann.org/p1lfb0cr39n
Second call AC Recording: https://participate.icann.org/p12zqjemvt2
** Please let me know if your name has been left off the list **
Mailing list archives of the GNSO Temp Spec gTLD RD EPDP : https://mm.icann.org/pipermail/gnso-epdp-team/

Main wiki page for the working group:  https://community.icann.org/x/IYEpBQ

Thank you.

Kind Regards,
Terri Agnew

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