[Gnso-epdp-team] Draft Letter to EDPB

[Plaut, Diane]

Agreed Thomas, I too have read it and think it needs further work. I have started making suggested edits through redline and we can begin to share and discuss.

Diane

Diane Plaut
General Counsel and Privacy Officer
[cid:image001.png at 01D3CA70.18FC1D40]
Direct +1 646-899-2806 
diane.plaut at corsearch.com<mailto:diane.plaut at corsearch.com>

220 West 42nd Street, 11th Floor, New York, NY 10036, United States
www.corsearch.com<http://www.corsearch.com/>
Join Corsearch on   Twitter<https://twitter.com/corsearch>  Linkedin<https://www.linkedin.com/company/2593860/>  Trademarks + Brands<http://trademarksandbrands.corsearch.com/>
Customer Service/Platform Support: 1 800 SEARCH1™ (1 800 732 7241)
Corsearch.USCustomerService at corsearch.com<mailto:Corsearch.USCustomerService at corsearch.com>

Confidentiality Notice: This email and its attachments (if any) contain confidential information of the sender. The information is intended only for the use by the direct addressees of the original sender of this email. If you are not an intended recipient of the original sender (or responsible for delivering the message to such person), you are hereby notified that any review, disclosure, copying, distribution or the taking of any action in reliance of the contents of and attachments to this email is strictly prohibited. If you have received this email in error, please immediately notify the sender at the address shown herein and permanently delete any copies of this email (digital or paper) in your possession.



From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Thomas Rickert <epdp at gdpr.ninja>
Date: Tuesday, November 27, 2018 at 2:58 PM
To: Kurt Pritz <kurt at kjpritz.com>
Cc: "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Draft Letter to EDPB

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.

Best,
Thomas



> 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>
>
> _______________________________________________
> Gnso-epdp-team mailing list
> Gnso-epdp-team at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-epdp-team<https://mm.icann.org/mailman/listinfo/gnso-epdp-team>

_______________________________________________
Gnso-epdp-team mailing list
Gnso-epdp-team at icann.org
https://mm.icann.org/mailman/listinfo/gnso-epdp-team<https://mm.icann.org/mailman/listinfo/gnso-epdp-team>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/gnso-epdp-team/attachments/20181127/f4f8503e/attachment-0001.html>
-------------- next part --------------
A non-text attachment was scrubbed...
Name: image001.png
Type: image/png
Size: 5570 bytes
Desc: image001.png
URL: <http://mm.icann.org/pipermail/gnso-epdp-team/attachments/20181127/f4f8503e/image001-0001.png>