[Gnso-epdp-team] Input requested on BC input in relation to recommendation 9

[Alan Woods]

Hey all,

Sorry to be the continuous wet blanket here, but again I need to call a
halt to overreach and assumptions.

The ORG process discussions regarding consent for that field, has always
been about consent obtained by the registrar for the registrar's processing
of the data. We have NOT discussed the transfer, or logging of this consent
by the registry, or how basic matters such as change of mind / article 17 /
subsequent opt-out of the registrant would be properly notified, achieved
or even legally arranged by the registry.

I therefore we do NOT support the additional line from the BC as written, a
as it completely circumvents the discussion necessary to achieve GDPR
compliance.

The Registries therefore will only support, *at this time*, the
recommendation as was discussed, and that is one that concerns the direct
relationship and consent of a registrant with the registrar. We therefore
propose the following update as clarification.


*After the implementation phase-in period, the ORG FIELD will no longer be
REDACTED by the registrar. *

NOTE: I will defer to my Registrar colleagues as to the assumptions of the
remainder of the insertion.

Alan



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Alan Woods
Senior Compliance & Policy Manager, Donuts Inc.
------------------------------
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On Wed, Feb 6, 2019 at 5:27 PM Marika Konings <marika.konings at icann.org>
wrote:

> Dear Registrar Team, all,
>
>
>
> Per today’s action item, you are requested to provide your input on the BC
> suggestion that in relation to recommendation 9 – Organization field:
>
> *“**Instead of a “via a process that can be determined by each
> registrar”   we should have concrete steps that can be enforced by ICANN.
> Could the registrars identify some reasonable steps for this process?*
>
>
>
> *ADD:  After the implementation phase-in period, the ORG FIELD will no
> longer be REDACTED by either the registry or registrar.  “*
>
>
>
> Your feedback on this input is appreciated.
>
>
>
> Thanks,
>
>
>
> Caitlin, Berry and Marika
>
>
>
> *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>  *
>
>
>
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>
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