[Gnso-epdp-team] Consensus call #2
epdp at gdpr.ninja
Wed Feb 13 19:17:05 UTC 2019
Dear Kurt, all,
for the record, I am happy to confirm the ISPCP’s support for the second batch of the consensus call. As mentioned for the first batch, this is conditional to the wording remaining unaltered. In case there are changes, Fiona and would need to take the new language back to the ISPCP.
I also add - again - a caveat for the last recommendation on "consent to publish additional information“, which I shared on the list earlier:
Let me just to on the record (again) that - whilst I do support that an opportunity for consent must be given at some point - we need to make sure this is done in a compliant fashion. As state previously, I do not think we have the technical and organizational means in place so that the controller(s) can demonstrate that the consent (and the contents thereof) have been given, see Art. 7 I GDPR. This is not impossible to do, but I think the gTLD ecosystem is not yet ready for handling consent and make it travel with the registration data to all players. I think some in our team think that we are operationally and legally ready to do that in a compliant fashion, in which case we should probably link to related documentation or write a few lines on how this can be done. In sum, I do not think it is just a matter of commercial factors.
All the best,
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