[Gnso-epdp-team] Updated lawful basis memo

Caitlin Tubergen caitlin.tubergen at icann.org
Mon Oct 8 15:10:14 UTC 2018

Dear All,


Following up on an action item from Tuesday’s call, please find the updated Lawful Basis memo, which now includes updated processing activities/rationales as well as notations when disagreement on the identified lawful basis was expressed. 


Please note the following when reviewing the document:

If you believe any of the newly-identified processing activities require the workbook data elements to be updated, please provide requested edits and the accompanying rationale to the list. If no updates are provided, we will assume the previously-designated data elements are sufficient for the updated processing activities.
At least one member of the EPDP Team requested to add a new processing activity to Purpose M; specifically, Margie noted an additional processing activity is transmission of registration information to the entity who files a UDRP/URS complaint. It is staff’s understanding that the UDRP Provider interacts directly with the registrar in order to obtain/confirm relevant registered name holder data, and the registrar, in turn, provides the relevant data to the Provider (who will then forward the info to the complainant or complainant’s counsel). As the disclosure of registration data to a UDRP/URS provider is already noted in the memo, it doesn’t appear that this additional processing activity is necessary, particularly because Purpose B may cover a situation where a trademark holder may contact the registrar directly for disclosure of non-public data. If this is either an inaccurate representation of the request for a new processing activity under M, or an inaccurate description of how data is conjunction with a UDRP/URS proceeding, please let us know.
If any members believe a processing activity(ies) is missing, please reply to the list.
Thank you.


Best regards,


Marika, Berry and Caitlin


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