[Gnso-epdp-team] Section 4.4.8

[Hadia Abdelsalam Mokhtar EL miniawi]

Hi Amr and Alex,

I would just like to note that I worked on your original proposal and that the modifications that I propose below is in compliance with article 5 1 (b) which speaks about specified, explicit and legitimate purposes.
The specific purpose of the processing of the data spelled out in  the document is to  "support a model that provides access to those with legitimate interests based on lawful grounds (which is the GDPR) to Registration Data relevant to addressing specific issues involving domain name registrations " If we end the sentence here it will be fine and GDPR compliant, however for clarification some additional lines are included to serve as examples of those who might have  legitimate interest. The text is also in compliance with article 61(f) which puts the legitimate interest as the ground for processing.

Hadia


From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] On Behalf Of Hadia Abdelsalam Mokhtar EL miniawi
Sent: Thursday, September 13, 2018 10:45 AM
To: Alex Deacon; gnso-epdp-team at icann.org
Subject: Re: [Gnso-epdp-team] Section 4.4.8

Hi All,

Dear Alex and Amr,

First off thank you  for your effort and time on this proposal. But are you saying that among the purposes of the processing of the data is the "  identification of third-parties with legitimate interests". This is surely not one of the purposes for the processing of the data therefore a suggest removing it.

So my suggestion would be.

4.4.8  Supporting a Model that provides access to parties with legitimate interests grounded in legal bases to Registration Data relevant to addressing specific issues involving domain name registrations; such as issues related to consumer protection, investigation of cybercrime, DNS abuse and intellectual property protection.

I put model as I think it is more specific but I am fine with using the term framework if you see it more appropriate. I also suggest adding  "such as issues related to"  which would serve to provide examples of third parties with legitimate interest.

Kind Regards
Hadia



From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] On Behalf Of Alex Deacon
Sent: Tuesday, September 11, 2018 10:34 PM
To: gnso-epdp-team at icann.org
Subject: [Gnso-epdp-team] Section 4.4.8

Hi All,

As you know a group of us has been working to recommend an update to Section 4.4.8 of the temp spec.

While we haven't come to full agreement on the update, we are pretty close and wanted to share the current/tentative output of the volunteer team with the broader team.

4.4.8  Supporting a framework that enables identification of third-parties with legitimate interests grounded in legal bases, and providing these third-parties with access to Registration Data relevant to addressing specific issues involving domain name registrations related to consumer protection, investigation of cybercrime, DNS abuse and intellectual property protection.

The non-bold text was suggested by Amr/NCSG and the added bold text was an updated suggested by me/IPC and supported by the BC.

Giving it a re-read again today I think additional word-smithing could be warranted, but for now I will resist and step away and let others share their thoughts.

Alex



--
___________
Alex Deacon
Cole Valley Consulting
alex at colevalleyconsulting.com<mailto:alex at colevalleyconsulting.com>
+1.415.488.6009

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