[Gnso-epdp-team] GAC statement to phase 1 final report

Thomas Rickert epdp at gdpr.ninja
Wed Feb 20 11:59:09 UTC 2019


All,
This discussion clearly underpins the point I made during the call yesterday (and on multiple occasions in the past). 

1. There should be one set of rules for contracted parties on a mandatory basis.
2. There should be a waiver process to allow for flexibility for contracted parties under certain circumstances.
3. The provision of certain data elements such as tech-c should be optional for the RNH (which legally qualifies as consent-based processing imho and needs proper legal implementation).

With all the confusion in our team on this topic, how shall users around the world cope with that challenge :-)?

Best,
Thomas 

> Am 20.02.2019 um 12:03 schrieb Hadia Abdelsalam Mokhtar EL miniawi <Hadia at tra.gov.eg>:
> 
> Hi again
> 
> Page 7 - footnote says  "for those data elements marked as "optional" these are optional for the RNH to provide
> 
> The Technical contact is addressed separately on page 8 where it says that it is optional for the registrar to provide
> 
> Hadia
> ________________________________________
> From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Hadia  Abdelsalam Mokhtar EL miniawi <Hadia at tra.gov.eg>
> Sent: 20 February 2019 12:40
> To: Heineman, Ashley; GNSO EPDP
> Subject: Re: [Gnso-epdp-team] GAC statement to phase 1 final report
> 
> Hi Ashley,
> 
> 
> I noticed in your attachment that you refer to the organization field as optional for the registrar to provide, according to the current report registrars are required to offer the organization field to the registrants but it is optional for the registrants to fill it in. The organization field will be published if the registrant agrees to that otherwise it can either be redacted or deleted depending on what the registrar decides to do. However there is a phase in period for the registrars with no certain date. So this is not like the tech contact field which is optional for the registrars to provide and optional for the registrants to fill in.
> 
> 
> Best
> 
> Hadia
> 
> ________________________________
> From: Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> on behalf of Heineman, Ashley <AHeineman at ntia.doc.gov>
> Sent: 20 February 2019 02:54
> To: GNSO EPDP
> Subject: [Gnso-epdp-team] GAC statement to phase 1 final report
> 
> Dear Kurt,
> 
> Please find attached a statement for including in the phase 1 final report from the GAC small group.  FWIW - this does NOT represent an objection to the consensus calls or the report itself.
> 
> Thanks kindly,
> 
> Ashley Heineman
> 
> 
> 
> Sent from my Verizon, Samsung Galaxy smartphone
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