[Gnso-epdp-team] Revised Recommendations for (Final) Review - with attachments
alan.greenberg at mcgill.ca
Mon Feb 4 22:33:19 UTC 2019
On Rec 12 - Reasonable Access, I believe that the criteria to be developed must include some reference to an average or median response time. Just providing the outer limit does not address the problem of determining whether the typical response is reasonable or not.
On Rec 10, you will recall that the Temp Spec reuires (after reasonable implementation delay) that REDACTED information be displayable with the consent of the data subject, but since e-mail addresses are not "redacted" it did not apply. I believe there was agreement that there must be a provision for a registrant to specify that their e-mail addresses display. That implies that part 1 should end with something like "... but MUST NOT identify the contact email address or the contact itself unless the registrant explicitly requests such display."
At 31/01/2019 11:31 PM, Kurt Pritz wrote:
Thanks again for your perseverance. And - thank you in advance for your spirit of cooperation and compromise in considering the attached. We have spent the last few days reviewing the transcripts and other records of our recent discussions and then amending the Final Report Recommendations - taking into account the Initial Report Recommendations, the small team work, the conclusions in Toronto and these last several meetings.
The Recommendations included here are:
Recommendation 5 - Data elements to be transferred from Registrars to Registries
Recommendation 10 - Email communication
Recommendation 12 - Reasonable Access
Recommendation 14 - Responsible Parties
[Not included are Rec. 13 (sent earlier) and Rec. 11 and the Research Purpose (to be sent tomorrow.]
Each of these documents has a brief forward containing a description of the pertinent discussion and an explanation for choosing the wording in the Recommendations. They each then contain the Recommendation as originally written and a redline of the proposed recommendation based on the most recent discussions. Please read the entire documents (they are not long), and not just the recommendation itself.
I am certainly not asking for you to stand silently by if you disagree with these Recommendations because they would negatively impact GDPR compliance. I am asking that you study the balancing that went into this and be ready to accept wording in cases where it does not match your own choice.
Please review with your groups and return to us by Monday so that we can put any of these on the Tues/Wed/Thur agendas.
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