[Gnso-epdp-team] Draft Letter to EDPB

Thomas Rickert epdp at gdpr.ninja
Tue Nov 27 13:58:02 UTC 2018

Hi Kurt,
I really enjoyed the „time off“, but unfortunately it was not without GDPR, but GDPR for clients and not for the EPDP :-).

Thanks for sharing the draft letter. I think it is a good starting point for a discussion, but I would not endorse sending it in its current form for two reasons:

1. We should discuss as a team what areas we want to get input on. 

The „legal basis for escrow“ point - to me - is not relevant enough to bother the EDPB with. I would rather bring purpose 2 and the question of a joint controller scenario to the attention of the EDPB.

2. We need to write more

We need to offer more background information to the EDPB. On natural vs. legal or the designation of third parties, we really need to put flesh to the bones and describe both the operational realities as well as the legal implications for the different scenarios more. The EDPB needs to be fed with all information relevant to their decision. We cannot expect them to know things or do research.


> Am 26.11.2018 um 23:55 schrieb Kurt Pritz <kurt at kjpritz.com>:
> Hi Everyone:
> I hope you all had a good break from GDPR. 
> Among our next steps is to send a letter to the European Data Protection Board with our questions. After reviewing the questions as posed in the Initial Report, I thought that some background, clarification and additional detail were required so that the EDPB is better able to understand our questions and is also better able to provide helpful responses. In collaboration with the Support team, we drafted the attached letter that we intend to send onto the EDPB shortly. As the EDPB meets monthly and their next meeting is next week, it is important that we send our questions as soon as possible. 
> Thanks in advance for taking time to read and consider this. 
> Best regards,
> Kurt
> <Letter EDPB - 26 Nov 2018(clean).docx>
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