[Gnso-epdp-team] Input on overview of purposes table - due by Friday 14 September at 19.00 UTC

Alex Deacon alex at colevalleyconsulting.com
Fri Sep 14 22:50:56 UTC 2018

Hi All,

You will see I added our input to the table as requested.

There are two comments I wanted to highlight.

First, regarding the suggestion that we "park" discussion on Section 4.4.2.
  The EPDP charter (Part 1 (a)) indicates that questions related to
Purposes (Sections 4.4.1-4.4.13) must be answered before work on a
standardized access model can commence. It goes on to say that purposes
relating to access “will inform decisions about how personal data in
registration data is processed. Because providing access to non-public
Registration Data is a processing activity, there must be a legitimate
purpose(s) with corresponding legal basis(es) established prior to granting
such access.”

As such the charter is explicit that the purpose described in Temp Spec
Section 4.4.2 can’t be “parked” and must be defined by the EPDP as a
prerequisite to further discussions on policy and methods/frameworks
related to access.

Second, the heading of Column H needs to be updated.  In the July 5 Letter
from Jelinek to Marby, the EDPB states “There are processing activities
determined by ICANN, for which ICANN, as well as the registrars and
registries, require their own legal basis and purpose, *and then there are
processing activities determined by third parties, which require their own
legal basis and purpose*”.

As the EDPB is asking for us to defined purposes and legal basis for
processing activities determined by third parties, column H should be
“Purposes determined by 3rd Party Interests”.


On Tue, Sep 11, 2018 at 11:00 AM Marika Konings <marika.konings at icann.org>

> Dear All,
> In relation to *Action item #7 *(EPDP Team to review overview of purposes
> table), please use the following Google Sheet for your input:
> https://docs.google.com/spreadsheets/d/1RivZFrPQpJ_bgDlOI6yfhhYaSs2oYgS1n4TObifAoJ8/edit?usp=sharing.
> You are requested to use the three last columns to provide your feedback.
> Make sure to include your name and affiliation with any comments that you
> enter.
> Team input to commence now and will finish *by 19.00 UTC on Friday 14
> September* to allow the leadership team to work with Thomas and Benedict
> to prepare the subsequent discussion on this overview.
> Best regards,
> Caitlin, Berry and Marika
> *Action item #7*: EPDP Team to review overview of purposes table and
> provide input on whether this provides an accurate picture. Focus should be
> on the purposes for collection and other processing (Registrar, Registry
> and ICANN), but not access (Third party interests) as these will be
> considered in further detail in the context of the standardized access
> discussion. Also consider whether purposes are sufficiently specific? Team
> input to commence  now and will finishby 19.00 UTC on Friday 14 September.
> Thomas and Benedict will take that input to create an agenda for the
> Tuesday meeting.
> *Marika Konings*
> *Vice President, Policy Development Support – GNSO, Internet Corporation
> for Assigned Names and Numbers (ICANN) *
> *Email: marika.konings at icann.org <marika.konings at icann.org>  *
> *Follow the GNSO via Twitter @ICANN_GNSO*
> *Find out more about the GNSO by taking our interactive courses
> <http://learn.icann.org/courses/gnso> and visiting the GNSO Newcomer pages
> <http://gnso.icann.org/sites/gnso.icann.org/files/gnso/presentations/policy-efforts.htm#newcomers>. *
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*Alex Deacon*
Cole Valley Consulting
alex at colevalleyconsulting.com
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