[Gnso-epdp-team] Recommendation 1 Purpose 1 - RrSG Comments

Sarah Wyld swyld at tucows.com
Fri Jan 25 21:14:01 UTC 2019

Hello All,

For Recommendation 1 Purpose 1, the RrSG has the following comments:

  * Rename this to: Further Processing of Data.

  * Within the ICANN context we want to process data collected for a
    different purpose to be further processed for research purposes
      o What is research within the ICANN context? And does it have
        scientific purposes?
      o Is the ARS Reporting system research, or as the name indicates a
        reporting system that flags possible incorrect data? And is this
        not already in scope of the GDPR?
      o Art 89 and relevant recitals in scope due to whatever research
        is within the ICANN context?
      o Depending on the research do Art 17 and 21 apply?
  * *In short with the above in mind, what does the WG think is research
    and does it require processing of personal data?*

Sarah Wyld
Domains Product Team
+1.416 535 0123 Ext. 1392


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