[Gnso-epdp-team] Data minimization and use of technical/admin contacts

Alan Greenberg alan.greenberg at mcgill.ca
Thu Oct 4 12:44:41 UTC 2018

I am sometimes amazed at our ability to debate 
issues where it is not warranted. We spend a 
significant amount of time on Tuesday on Tech and 
Admin contacts (both voice and a lot in the chat).

Among other things, the principle of data minimization was sited.

The EDPB letter of 05 July 2018 says:

>The EDPB considers that registrants should in 
>principle not be required to provide personal data
>directly identifying individual employees (or 
>third parties) fulfilling the administrative or technical
>functions on behalf of the registrant. Instead, 
>registrants should be provided with the option of
>providing contact details for persons other than 
>themselves if they wish to delegate these functions·
>and facilitate direct communication with the 
>persons concerned. It should therefore be made clear,
>as part of the registration process, that the 
>registrant is free to ( 1) designate the same person as the
>registrant (or its representative) as the 
>administrative or technical contact; or (2) provide contact
>information which does not directly identify the 
>administrative or technical contact person
>concerned (e.g. admin @company.com). For the 
>avoidance of doubt, the EDPB recommends
>explicitly clarifying this within future updates 
>of the Temporary Specification.

We are told that in one case, 30% of registration 
done by resellers use those field for unique 
data. We know many legal persons do.

If the EDPB is ok with such collection (with 
appropriate warnings), and many registrants use 
the fields, why do we need to re-debate it. 
Aren't there enough substantive issues to focus on?


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