[Gnso-epdp-team] Data Processing and data disclosure

[Kavouss Arasteh]

 | Dear Thomas,

In discussing  Data Processing  Data Disclosure today

*Let me bring to your kind attention the followings;:*

*Some elementary dedfinition of data proccessing*

*"Data processing is t**he conversion of data into usable and desired
form. **This conversion or “processing” is carried out using a predefined
sequence of operations either manually or automatically. Most of the data
processing is done by using computers and thus done automatically. The
output or “**processed”** data can be obtained in different forms like
image, graph, table, vector file, audio, charts or any other desired format
depending on the software or method of data processing used *

Data processing  may involve

   - Validation  – Ensuring that supplied data is correct and relevant.
   - sorting – "arranging items in some sequence and/or in different sets."
   - Summarization – reducing detail data to its main points.
   - Aggregation – combining multiple pieces of data.
   - Analysis – the "collection, organization  analysis, interpretation and
   presentation of data."
   - Reporting – list detail or summary data or computed information.
   - Classification – separation of data into various categories.

Data processing also referred to as "the collection  and manipulation of
items of data to produce meaningful information. In this sense it can be
considered a subset of *information processing *, "the change (processing)
of information in any manner detectable by an observer."

Having said that I wish to recall that :

1. you referred to Article 2 of GPDR stating that data proccessing is
associated with sata disclosure in that Article.May you kindly advise which
part of Article 2 such reference  is made

2. You talked about data disclosure while we were discussing Data Access or
Data Transfer these are totally different things

3. If anyone says that Data Transfer or data access is part of data
process, it is  not totally valid .It is preferable that analysis of these
two totally different issues  be done from technical point of view  and are
left to technical people

One can once collects data does make  nothing  or either transfer that
unprocessed data to a recipient or record that data elsewhere . That entity
could also process the date (,Data Processing  ) as described above.

I therefore request you to kindly make difference between " Data Process" ,
",Data transfer " which may roughly referred as " Data Transfer ".

One should allow the  expert in data Communication express their views
without misleading by mixing " Data Process" , ",Data transfer " which may
roughly referred as " Data Transfer ".

When people refers to GDPR needs to recognized that the authors were mostly
administrative and legal people without engineering background. They
normally good to write theoretical text in form of policy without
acknowledging their implementations

For some of us data Access may have little sense whereas for many others
the  purpose of Data Access , among other things are  law enforcement,
combating cybercrime, countering cyber-attack and preserve the security,
stability and resiliency of DNS not merely from preservation of commercial
interests but for establishing/ maintaining public order

Regards

Kavouss
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