[Gnso-epdp-team] For Final Review - Initial Report - deadline Wednesday 21 November at 18.00 UTC

Thomas Rickert epdp at gdpr.ninja
Wed Nov 21 15:21:19 UTC 2018

Hi Trang,
Thanks so much for the additional comments. As you suggest, I think these should not stop us from releasing the report. 

Let’s be clear, there will be work involved in getting the compliance done and we should try to get contracts as standardized as possible and use existing mechanisms to get the contracts in place (hence my idea to use the RRA). Maybe it is just me, but I read those comments like we are suggesting something that is overly cumbersome to implement, which suggests that you might have a envisaged solution that requires less efforts. If so, please do share. 

Just to illustrate this:

Where we have a joint controller situation, we need JCAs
Where we have controller-processor situations, we need DPAs
Where we have independent controller situations, we would at least need to cover (as for the other two scenarios) the non-EU transfers in writing

In sum, regardless what option we pursue, we will need to formalize the relationships. 

If anyone has an idea of how to avoid formalities, please share. If there is no way to avoid formalities, let’s just accept that and try to find the most efficient way to get that done.


> Am 21.11.2018 um 06:42 schrieb Trang Nguyen <trang.nguyen at icann.org>:
> Dear EPDP Team,
> Regarding recommendation #13, as we flagged today in the chat and previously provided in the ICANN feedbackdocument <https://mm.icann.org/pipermail/gnso-epdp-team/2018-November/000895.html>, there are implementation-related issues and concerns that we look forward to continuing to discuss with the Team. For example, the practicality as well as cost of negotiating, monitoring, supporting, and enforcing 1200+ different agreements with potentially different obligations. We’d also like to flag some additional suggestions and questions on recommendation #13. For easy viewing, we extracted recommendation #13 from the draft Initial report and provided the suggestions and questions in the comment fields. To be clear, we do not believe that these items should delay publication of the Initial Report. We look forward to continued discussion with the EPDP Team on this topic.
> The one thing that we do want to flag for the EPDP Team’s consideration prior to the publication of the Initial Report is the inconsistency in how recommendation #13 is displayed in Section 2 and Section 4 of the Initial Report. Section 2 only contains 2 paragraphs while Section 4 contains these two paragraphs plus several paragraphs of additional text. Since the additional text does not appear in Section 2 of the report, we assume it is not part of the recommendation. If this assumption is correct, it would be helpful to make the separation of the additional text clearer in Section 4 of the report.
> Dan and Trang
> ICANN org liaisons
> From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org <mailto:gnso-epdp-team-bounces at icann.org>> on behalf of Marika Konings <marika.konings at icann.org <mailto:marika.konings at icann.org>>
> Date: Tuesday, November 20, 2018 at 11:46 AM
> To: "Gnso-epdp-team at icann.org <mailto:Gnso-epdp-team at icann.org>" <Gnso-epdp-team at icann.org <mailto:Gnso-epdp-team at icann.org>>
> Subject: [Gnso-epdp-team] For Final Review - Initial Report - deadline Wednesday 21 November at 18.00 UTC
> Dear EPDP Team, <>
> We are pleased to share the proposed Initial Report for publication. Thank you again for attending and constructively contributing to the many hours of meetings over the past few days.
> Redline – https://drive.google.com/a/icann.org/file/d/171jOv42nahKFnPW1WhSE8ckr6K00i4RX/view?usp=sharing [drive.google.com] <https://urldefense.proofpoint.com/v2/url?u=https-3A__drive.google.com_a_icann.org_file_d_171jOv42nahKFnPW1WhSE8ckr6K00i4RX_view-3Fusp-3Dsharing&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=NghSLFqweTwAOFMJpbYA3LcVJ0Vvvw6-wxrKoS5l6VY&m=EsM_gBHmxSFPAzJp3M67DbigIhZDtEFi7WicX3tz3RQ&s=3J4Yh6TGbOOGChMPq_9L97rAO_AHWQaBNjw03jVhv-s&e=>
> Clean – https://drive.google.com/a/icann.org/file/d/1OyG6ExIGkemW902jHYF7V88Y8mu-kObk/view?usp=sharing [drive.google.com] <https://urldefense.proofpoint.com/v2/url?u=https-3A__drive.google.com_a_icann.org_file_d_1OyG6ExIGkemW902jHYF7V88Y8mu-2DkObk_view-3Fusp-3Dsharing&d=DwMGaQ&c=FmY1u3PJp6wrcrwll3mSVzgfkbPSS6sJms7xcl4I5cM&r=NghSLFqweTwAOFMJpbYA3LcVJ0Vvvw6-wxrKoS5l6VY&m=EsM_gBHmxSFPAzJp3M67DbigIhZDtEFi7WicX3tz3RQ&s=ASqrI8ZnjDf6jUM_k0_3nQgyvS2Gam5oREH-MqPMaew&e=>
> Note that in the redline version, you will find highlighted in yellow the updates proposed by Thomas for the responsibilities section. He also spotted some inconsistencies in the related tables that have been updated accordingly (as well as the related data elements workbooks sections). Please also note that per Monday’s discussion, the summary has been split out into an Executive Summary and Overview of Preliminary Recommendations.
> For your convenience, you will also find attached the clean Word version. However, should you spot any minor issues or show stoppers, please use the line number reference in the pdf version to facilitate locating the language. Minor issues (e.g. grammatical, readability) can be sent to staff off list.
> Due to internal ICANN processing times and deadlines we require feedback by 1800 UTC, tomorrow, 21 November. If you need additional time (not more than two hours), you must notify us before the 1800 cut off.  
> Best regards,
> Caitlin, Berry and Marika
> Marika Konings
> Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN) 
> Email: marika.konings at icann.org <mailto:marika.konings at icann.org>  
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