[Gnso-epdp-team] Recommendation 12 - Reasonable Access

Plaut, Diane Diane.Plaut at corsearch.com
Thu Feb 7 03:31:45 UTC 2019

Dear All-

Thank you to the great work of Sarah, Kristina, Alex and others. We are looking to move this Rec forward and have worked to further clarify and edit the language - taking into account comments by all. Therefore, please find the attached proposed updated Rec. 12 for further discussion tomorrow.

Sincerely, Diane

Diane Plaut
General Counsel and Privacy Officer
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From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Hadia Abdelsalam Mokhtar EL miniawi <Hadia at tra.gov.eg>
Date: Wednesday, February 6, 2019 at 5:35 AM
To: Marika Konings <marika.konings at icann.org>, Sarah Wyld <swyld at tucows.com>, "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
Subject: Re: [Gnso-epdp-team] Recommendation 12 - Reasonable Access

Hi all, the below comments are on behalf of Alan G

the proposal.

1. still does not set an expectation that although SOME requests may take the specified limit, not all should. Nor does it seem to imply that the Contractual Compliance has any ability to audit response times.

2. I find the reference to "GDPR legal bases" problematic. For example, under the current proposals, a registrar who is operating full outside of the EU mat redact information for legal persons and for natural persons not subject to the GDPR. What is the GDPR legal basis for requesting information on such registrations. According to GDPR there was no need for redaction to begin with, so a registrar can refuse to provide any results with full impunity.

From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces at icann.org] On Behalf Of Marika Konings
Sent: Tuesday, February 05, 2019 11:43 PM
To: Sarah Wyld; gnso-epdp-team at icann.org
Subject: Re: [Gnso-epdp-team] Recommendation 12 - Reasonable Access

Thanks, Sarah.

EPDP Team members, as this topic is included in the agenda for tomorrow’s meeting, please share any issues or concerns your group may have with the modified language prior to the meeting, if possible. Staff has taken the liberty to fix some formatting issues in the attached version (some of the sub-bullets did not appear properly).

Best regards,

Caitlin, Berry and Marika

From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Sarah Wyld <swyld at tucows.com>
Organization: Tucows
Date: Tuesday, February 5, 2019 at 12:31
To: "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
Subject: [Gnso-epdp-team] Recommendation 12 - Reasonable Access

Hello All,

As discussed on today's call, here is the proposed revised Rec. 12 from RySG/RrSG. Thank you.


Sarah Wyld

Domains Product Team


+1.416 535 0123 Ext. 1392

On 1/31/2019 11:31 PM, Kurt Pritz wrote:

Hello Everyone:

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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