[Gnso-epdp-team] Fwd: ISPCP input to draft final report

Thomas Rickert epdp at gdpr.ninja
Tue Feb 19 16:14:06 UTC 2019

I just heard that the below note may not have made it to the list. 

Anfang der weitergeleiteten Nachricht:

> Von: Thomas Rickert <thomas at rickert.net>
> Datum: 18. Februar 2019 um 14:26:27 MEZ
> An: "gnso-epdp-team at icann.org" <gnso-epdp-team at icann.org>
> Kopie: Thomas Rickert <thomas at rickert.net>
> Betreff: ISPCP input to draft final report
> Kurt, all,
> please find below the statement on the draft final report from the ISPCP in addition to the input already provided on the first and second batch of the consensus call.
> Recommendation 5 - optional Tech-C:
> Whilst not opposing recommendation 5, we would like our concern to be noted that our goal should be to have one system that works globally for gTLDs to avoid fragmentation. Therefore, we recommend to amend this recommendation so that 
> - the registrar MUST offer the option to provide data for the tech-c and
> - the provision of data for a tech-c is optional
> Users should get the same experience and options regardless of what registrar they choose to work with.
> Recommendations 10 / 16 and 17:
> We think that more work needs to be done in order to provide for a system that is globally applicable to avoid fragmentation in terms of RNH rights and user experience. 
> Recommendation 18:
> We suggest to include the timelines / procedure as laid down in Art. 15 III GDPR so that there is transparency regarding response times:
> The clause reads:
> 1The controller shall provide information on action taken on a request under Articles 15 to 22 to the data subject without undue delay and in any event within one month of receipt of the request. 2That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. 3The controller shall inform the data subject of any such extension within one month of receipt of the request, together with the reasons for the delay. 4Where the data subject makes the request by electronic form means, the information shall be provided by electronic means where possible, unless otherwise requested by the data subject.
> Additionally, we suggest to include a requirement for contracted parties to publish data on how many disclosure requests they get. That helps the community understand whether response times are corresponding with work load. 
> Recommendation 19:
> The EPDP Team chose to dilute the language of this recommendation not to make reference to a specific legal vehicle. As a matter of compromise, reference to the analysis in the report was agreed to be made to inform the implementation and decision on what legal vehicle to use. The report now includes amended language as prepared by ICANN representatives. These changes were not discussed by the EDPDP team and we ask to reinstate the original language of the report to inform the decision-making during the implementation of the recommendation.
> Recommendation 27:
> We support the recommendation as long as it is ensured that
> the community is part of the implementation team
> the GNSOCouncil as the policy manager has the last saying on any policy amendments according to its PDP rules
> Thomas Rickert
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