[Gnso-epdp-team] For your review - Clarifying Legal Questions Table
Volker Greimann
vgreimann at key-systems.net
Mon Jun 3 10:06:20 UTC 2019
Hi Brian,
this is actually a funny argument you are trying to make here. You are
essentially saying registrants are getting their rights violated by
themselves, since they are the ones providing the data in the first
place. I would be very intrigued to see how the data subject feeling
violated this way would make this argument in court.
The only correct way to understand this right to accuracy is that it
relates to the right of correction, which means that the processor is
not entitled to change the data, must store the data provided correctly
and update it if necessary or requested by the data subject.
It is not the role of the processor or controller under the GDPR to tell
the data subject to correct the data they themselves provided. If
anything, such a requirement may be a business consideration, but it is
not something flowing out of the GDPR.
Best,
Volker
Am 31.05.2019 um 01:19 schrieb King, Brian via Gnso-epdp-team:
>
> Hi all,
>
> I boil this down to a couple key facts:
>
> 1) Data subjects have a right to data accuracy under GDPR, and 2) the
> data analysis shows that they’re not getting it in today’s
> registration data system (56% is a failing score by any measure, and
> especially in the context of fundamental rights). So accuracy falls
> squarely within the context of this EPDP.
>
> As it pertains to third parties, I suppose it’s fair to distinguish
> between a data subject’s _/right/_ and a third party’s _/need/_ for
> accurate data, but third-party needs are also provided for under GDPR,
> so the distinction is irrelevant as to whether they’re in scope for
> this EPDP. For example, an EBERO may not have an explicit, GDPR-given
> right to registration data, but the EBERO needs accurate data in order
> to allocate the domain name to its rightful owner when a registry
> implodes. This processing might be on a 6.1(a),(b),(e), or other
> basis; regardless, it’s a GDPR-compliant processing need. A phishing
> victim may not have an explicit, GDPR-given right to registration
> data, but EU case law is clear that pursuit of a legal claim wins the
> 6.1(f) test over privacy interests, so the victim has a GDPR-compliant
> processing need for accurate data to know who to name as defendant and
> where to file the lawsuit.
>
> So, accuracy and third-party needs are both in scope.
>
> I’m happy to answer any questions and/or work with the legal committee
> to prioritize any questions to the Birdies as the EPDP team deems
> prudent.
>
> *Brian J. King***
>
> *Director of Internet Policy & Industry Affairs*
>
> *MarkMonitor */ *Part of Clarivate Analytics *
>
> Phone: +1 (443) 761-3726
>
> brian.king at markmonitor.com <mailto:brian.king at markmonitor.com>
>
> *From:* Gnso-epdp-team <gnso-epdp-team-bounces at icann.org> *On Behalf
> Of *Mueller, Milton L
> *Sent:* Thursday, May 30, 2019 1:47 PM
> *To:* Margie Milam <margiemilam at fb.com>;
> Georgios.TSELENTIS at ec.europa.eu; vgreimann at key-systems.net
> *Cc:* gnso-epdp-team at icann.org
> *Subject:* Re: [Gnso-epdp-team] For your review - Clarifying Legal
> Questions Table
>
> Margie
>
> Your numbers show a decline in the accuracy of Whois reg data PRIOR to
> the implementation of the temp spec (June 2018 - temp spec went into
> effect late May 2018)
>
> That's interesting. So - all that indiscriminate public disclosure and
> all those policy measures intended to force registrants upon pain of
> death (of their registration) failed to maintain the desired level of
> accuracy. Very interesting indeed.
>
> Did it ever occur to you that the indiscriminate publication of Whois
> data might actually _cause_ much of the inaccuracy, by undermining the
> registrant's willingness to provide accurate data?
>
> Anyway I do not see what relevance this has to the EPDP's main
> project, which is to make the Whois GDPR compliant. First, the data do
> not measure the impact of GDPR compliance. Second, numerous people on
> this list have proven, again and again, that accuracy in GDPR is a
> data subject's right not a third party's right. Hence, ICANN policies
> intended to make the data accurate for third party demands have little
> to do with GDPR compliance.
>
> Insofar as current ICANN policy relies on GDPR-violating methods to
> ensure accuracy (e.g. publication of all data) those methods must be
> modified.
>
> Insofar as current ICANN policies designed to ensure accuracy are
> compliant with GDPR, then they can and will remain in place until
> modified by some other PDP. Ergo, ICANN's accuracy policies are not
> relevant to this proceeding. (Sorry, Georgios)
>
> --MM
>
> ------------------------------------------------------------------------
>
> *From:*Margie Milam <margiemilam at fb.com <mailto:margiemilam at fb.com>>
> *Sent:* Thursday, May 30, 2019 12:46 PM
> *To:* Georgios.TSELENTIS at ec.europa.eu
> <mailto:Georgios.TSELENTIS at ec.europa.eu>; vgreimann at key-systems.net
> <mailto:vgreimann at key-systems.net>; Mueller, Milton L
> *Cc:* gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>
> *Subject:* Re: [Gnso-epdp-team] For your review - Clarifying Legal
> Questions Table
>
> Georgios & All –
>
> Thank you for the reply. With regard to accuracy – please note that
> the latest accuracy report posted by ICANN in June, 2018 noted a
> *decline* in accuracy rates. It reported that only 56% of domains
> passed all operability tests, a decrease from Cycle 5 (63% in Dec
> 2017). With a 44% inaccuracy rate – this points to the need for us
> to examine whether the current rules/policies incorporated in the
> ICANN contracts are robust enough to produce a GDPR compliant system.
>
> All the best,
>
> Margie
>
> *From: *Gnso-epdp-team <gnso-epdp-team-bounces at icann.org
> <mailto:gnso-epdp-team-bounces at icann.org>> on behalf of
> "Georgios.TSELENTIS at ec.europa.eu
> <mailto:Georgios.TSELENTIS at ec.europa.eu>"
> <Georgios.TSELENTIS at ec.europa.eu <mailto:Georgios.TSELENTIS at ec.europa.eu>>
> *Date: *Thursday, May 30, 2019 at 4:12 AM
> *To: *"vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>"
> <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>>,
> "milton at gatech.edu <mailto:milton at gatech.edu>" <milton at gatech.edu
> <mailto:milton at gatech.edu>>
> *Cc: *"gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>"
> <gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>>
> *Subject: *Re: [Gnso-epdp-team] For your review - Clarifying Legal
> Questions Table
>
> Dear Volker, Milton, EPDP colleagues,
>
> I am reading with great interest the reactions to the clarification
> questions we sent, in particular regarding accuracy. The mere fact
> that the community has different understandings as to what exactly it
> means in the WHOIS policy reform under GDPR begs for asking those
> questions and not putting the issue (again) under the carpet. We might
> come with an outcome that current accuracy measures are sufficient for
> WHOIS GDPR compliance, or that we need more to do. Anyhow at this
> stage those are _clarification questions_ not a policy per se so I
> would welcome first the legal counsel to provide some informed opinion
> before any community jumping to conclusions.
>
> Best regards,
>
> Georgios
>
> *From:*Gnso-epdp-team <gnso-epdp-team-bounces at icann.org
> <mailto:gnso-epdp-team-bounces at icann.org>> *On Behalf Of *Volker Greimann
> *Sent:* Wednesday, May 29, 2019 6:54 PM
> *To:* gnso-epdp-team at icann.org <mailto:gnso-epdp-team at icann.org>
> *Subject:* Re: [Gnso-epdp-team] For your review - Clarifying Legal
> Questions Table
>
> Hi Margie,
>
> the risk of the poor registrant losing his domain name due to
> inaccurate whois data is actually entirely of ICANNs making as
> contracted parties certainly do not need this data set for the
> purposes of maintaining the registration. We have account data for
> that. The only reason whois inaccuracies can cause a registrant to
> lose his domain is ICANN policies and contractual obligations
> regarding failures to update inaccurate data and registrars opting for
> deletion instead of deactivation (do such registrars still exist?).
>
> For all other purposes reasonable steps are already being taken, as I
> explained in my previous mail.
>
> Best,
>
> Volker
>
> Am 29.05.2019 um 18:38 schrieb Margie Milam:
>
> Hi Chris and all –
>
> To answer your question, the legal advice provided by Bird & Bird
> on accuracy addresses this issue and notes that there is a
> positive obligation on the controller to ensure the data is
> accurate depending on the circumstances and the consequences of
> processing inaccurate data. It also notes that a controller may
> have to get independent confirmation where the impact is
> particularly significant. In addition, the issue of data accuracy
> as part of a GDPR compliant system was also raised by the European
> Commission in its recent comments to the Board.
>
> In the case of domain names, the consequence of inaccurate data
> affects not just the registrant (who could lose its domain name),
> but those that may be trying to resolve technical issues,
> cyber-crime or consumer protection issues. We also have numerous
> studies conducted by ICANN over the last decade that show
> unacceptable levels of accuracy in the WHOIS system. This is why
> the question of accuracy was pushed to Phase 2 in our Phase 1
> Final Report so that we could explore these issues further. See
> Footnote 6 where it says: /The topic of accuracy as related to
> GDPR compliance is expected to be considered further as well as
> the WHOIS Accuracy Reporting System./
>
> All the best,
>
> Margie
>
> *From: *Gnso-epdp-team <gnso-epdp-team-bounces at icann.org>
> <mailto:gnso-epdp-team-bounces at icann.org> on behalf of Chris
> Disspain <chris.disspain at board.icann.org>
> <mailto:chris.disspain at board.icann.org>
> *Date: *Tuesday, May 28, 2019 at 9:48 AM
> *To: *"gnso-epdp-team at icann.org" <mailto:gnso-epdp-team at icann.org>
> <gnso-epdp-team at icann.org> <mailto:gnso-epdp-team at icann.org>
> *Subject: *Re: [Gnso-epdp-team] For your review - Clarifying Legal
> Questions Table
>
> Greetings All,
>
> I’m a little confused by this discussion. Apologies in advance if
> the below is wrong or naive or has been covered before.
>
> I don’t understand the connection between accuracy and GDPR.
>
> The regulations govern a registrars right to collect the data and
> what they can do with it. Assuming they have that right under
> GDPR, the registrants obligation to provide them with *accurate*
> data is not governed by GDPR but rather the contractual
> relationship between registrar and registrant and the registrar is
> entitled to require accurate information from the registrant
> pursuant to that. The registrar can also require the updating of
> changed information and/or proactively seek re-confirmation of
> accuracy. And ICANN, in its contract with a registrar, can require
> that registrar to require the registrant to provide accurate
> information.
>
> Other than governing the right to collect the information (and
> what can be done with it) does GDPR have some other role that I’m
> missing?
>
> Cheers,
>
> Chris
>
>
> On 28 May 2019, at 17:23, Volker Greimann
> <vgreimann at key-systems.net <mailto:vgreimann at key-systems.net>> wrote:
>
> Didn't we have (and settle) the same argument about six months
> ago?
>
> This principle is a protection of the data subject. When we
> create personal data from the data provided to us by the data
> subject or a third party, we must ensure we store it
> accurately and our processing does not falsify it.
>
> As such, the contractual provision that the data subject must
> provide to us accurate data (and keep uit updated when it
> changes) and the confirmation of the accuracy by the data
> subject is sufficient for our purposes and therefore
> reasonable in accordance with this principle.
>
> The principles protect the data subject, not third parties.
>
> Can we now please stop going over old settled issues?
>
> Volker
>
> Am 28.05.2019 um 18:06 schrieb Greg Aaron:
>
> Milton, no, the word “accuracy” does not appear only in
> GDPR Article 18. It appears most prominently in Article
> 5, which says:
>
> Art. 5 GDPR Principles relating to processing of personal data
>
> "1. Personal data shall be: ... (d) accurate and, where
> necessary, kept up to date; every reasonable step must be
> taken to ensure that personal data that are inaccurate,
> having regard to the purposes for which they are
> processed, are erased or rectified without delay
> (‘accuracy’);…
>
> 2. The controller shall be responsible for, and be able
> to demonstrate compliance with, paragraph 1
> (‘accountability’).”
>
> There has been discussion in legal and GDPR compliance
> communities that the above means all of these:
>
> a) Controllers have some responsibilities to take positive
> steps to ensure data collected from subjects is accurate.
>
> b) Organizations must allow data subjects to rectify
> inaccuracies. (Your point.)
>
> c) The data controller must carefully consider any
> challenges to the accuracy of information – no matter
> where that challenge comes from.
>
> d) Organizations must identify essential steps to erase or
> rectify inaccurate data without delay. And,
>
> e) Within some limits, the parties to a Date Sharing
> Agreement are free to agree on terms and conditions
> applicable to their sharing of data – for example specific
> obligations and warranties about the accuracy and
> completeness of data.
>
> How far the above extend, and how they apply to RDS data,
> is a Phase 2 subject for exploration.
>
> GDPR certainly discourages the submission or maintenance
> of data that is incorrect or misleading. And Article 5
> seems to mean more than “trust implicitly whatever the
> data subject says, and correct the data only if the data
> subject itself requests.” The GDPR may contain some
> balancing mechanisms here, and proportionality is a
> general principle of EU law.
>
> So, given all that, and because there’s not a common
> understanding within our group, these issues are
> definitely good ones to ask Bird & Bird about.
>
> All best,
>
> --Greg
>
> *From:*Gnso-epdp-team <gnso-epdp-team-bounces at icann.org>
> <mailto:gnso-epdp-team-bounces at icann.org> *On Behalf Of
> *Mueller, Milton L
> *Sent:* Saturday, May 25, 2019 9:18 AM
> *To:* Georgios.TSELENTIS at ec.europa.eu
> <mailto:Georgios.TSELENTIS at ec.europa.eu>;
> caitlin.tubergen at icann.org <mailto:caitlin.tubergen at icann.org>
> *Cc:* gnso-epdp-team at icann.org
> <mailto:gnso-epdp-team at icann.org>
> *Subject:* Re: [Gnso-epdp-team] For your review -
> Clarifying Legal Questions Table
>
> Dear Georgios and colleagues:
>
> I think the questions related to accuracy below are not
> worth sending to the lawyers.
>
> They are based on a fundamental misconception, one which
> we have identified many times. Accuracy in GDPR and other
> data protection law is a right _/of the data subject/_,
> not a right of third parties to accurate data about the
> data subject.
>
> To prove this, beyond a shadow of the doubt, let me note
> that the word “accuracy” appears in GDPR in only two
> places, in Art 18.
>
> Article 18, Right to restriction of processing:
>
> -----------------------------------------------------------
>
> “The data subject shall have the right to obtain from the
> controller restriction of processing where one of the
> following applies: the accuracy of the personal data is
> contested by the data subject, for a period enabling the
> controller to verify the accuracy of the personal data;”
>
> So data subjects can contest the accuracy of data about
> them, or require controllers to verify its accuracy. There
> is NO OTHER reference to accuracy in the entire GDPR.
>
> Georgios’s questions are based on the assumption that
> third parties have a right to accurate contact data about
> the data subject. That assumption was embedded in the old
> Whois and pre-GDPR Whois accuracy policies, all of which
> were predicated on indiscriminate publication of the
> contact data to any and all third parties. That regime is
> gone. And it’s recognized even by the most militant
> pro-surveillance interests that such indiscriminate
> disclosure is illegal.
>
> Likewise, Georgios asks about liability under Article 82
> of GDPR. Again all we need to do is actually read Art 82
> to find the answer:
>
> Article 82 says “Any person who has suffered material or
> non-material damage as a result of an infringement of this
> Regulation shall have the right to receive compensation
> from the controller or processor for the damage suffered.”
> So this is a right of PERSONS (data subjects) to
> compensation based on illegal acts of controllers and
> processors of THEIR data. It is not a right of third
> parties to accurate information about the data subject,
> and it certainly creates no liability for controllers or
> processors for the inaccuracy of the registrants’ data.
>
> Dr. Milton L Mueller
>
> Georgia Institute of Technology
>
> School of Public Policy
>
> *From:*Gnso-epdp-team <gnso-epdp-team-bounces at icann.org
> <mailto:gnso-epdp-team-bounces at icann.org>> *On Behalf Of
> *Georgios.TSELENTIS at ec.europa.eu
> <mailto:Georgios.TSELENTIS at ec.europa.eu>
> *Sent:* Friday, May 24, 2019 7:02 PM
> *To:* caitlin.tubergen at icann.org
> <mailto:caitlin.tubergen at icann.org>
> *Cc:* gnso-epdp-team at icann.org
> <mailto:gnso-epdp-team at icann.org>
> *Subject:* Re: [Gnso-epdp-team] For your review -
> Clarifying Legal Questions Table
>
> Dear Caitlin, colleagues,
>
> Please find below questions on the topics of the legal
> memos from the GAC:
>
> *Accuracy*
>
> . If current verification statistics provide that a large
> number of data is inaccurate isn't that a metric to deduce
> that the accuracy principle is not served in a reasonable
> manner as demanded by the GDPR?
>
> . According to the GDPR all personal data are processed
> based on the principle that they are necessary for the
> purpose for which they are collected. If those data are
> necessary, how can the purpose be served while the data
> are inaccurate?
>
> . Can you provide an analysis on the third-parties
> mentioned in para 19 on which "ICANN and the relevant
> parties may rely on to confirm the accuracy of personal
> data if it is reasonable to do so"? Do they become in such
> a scenario data processors?
>
> . How does the accuracy principle in connection to the
> parties' liability has to be understood in light of the
> accountability principle of the GDPR? What are the
> responsibilities of ICANN and the contracted parties (who
> are subject to the GDPR) under Chapter IV pf the GDPR? If
> the contracted parties (as data controllers) engage third
> entities as processors (e.g. to provide data back-up
> services), what are the responsibilities of these
> entities? What does this mean in terms of liabilities (in
> light of Art. 82 GDPR)?
>
> . While in the first place it is up to the registrants to
> provide accurate details about themselves and it is up to
> the registrants not to mistakenly identify themselves as
> natural or legal persons, the Memo on "Natural vs Legal
> persons" provides interesting ideas/suggestions for the
> contracted parties to proactively ensuring the reliability
> of information provided, including through measures to
> independently verify the data. Could similar mechanisms be
> identified also for ensuring the reliability of the
> contact details of the registrant? Can best practices be
> drawn from the ccTLD?
>
> *Natural or non-natural persons*
>
> . How is the (inaccurate or accurate) designation by the
> registrant about her status as non-natural person
> considered personal data information? If it's not is the
> analysis about whether the accuracy principle applies
> relevant?
>
> . How would the analysis provided take into account the
> possibility for registrants who are natural persons to
> "opt-in" for a full publication of their personal data?
> Indeed it might be the case that some of these registrants
> might wish to ensure their details are available on WHOIS.
>
> *Technical contact *
>
> Most of the issue for not allowing this seems to be around
> the inability to verify if the RNH has obtained consent
> from the technical contact. When the CP's verify the email
> address could consent also be confirmed for the term of
> the registration?
>
> *General question:*
>
> . How could anonymisatio/pseudonymisation techniques be of
> help in complying with the GDPR while also allowing for
> additional disclosure of certain data elements? E.g. use
> of anonymised/pseudonymised emails and names, in
> particular in the context of registrations by legal persons.
>
> Apologies again for the delay of our submission.
>
> Georgios Tselentis (GAC-EPDP)
>
> *From:*Gnso-epdp-team <gnso-epdp-team-bounces at icann.org
> <mailto:gnso-epdp-team-bounces at icann.org>> *On Behalf Of
> *Caitlin Tubergen
> *Sent:* Wednesday, May 22, 2019 5:22 PM
> *To:* gnso-epdp-team at icann.org
> <mailto:gnso-epdp-team at icann.org>
> *Subject:* [Gnso-epdp-team] For your review - Clarifying
> Legal Questions Table
>
> Dear EPDP Team,
>
> Following up on an action item from our last meeting,
> please find attached a table which organizes the
> clarifying legal questions received to date. We will
> discuss the table during our next meeting.
>
> Please note that the deadline for submitting additional
> clarifying questions is before 14:00 UTC on Thursday, 23
> May. If additional questions come in before the deadline,
> we will update the table accordingly.
>
> Thank you.
>
> Best regards,
>
> Marika, Berry, and Caitlin
>
>
>
>
> _______________________________________________
>
> Gnso-epdp-team mailing list
>
> Gnso-epdp-team at icann.org <mailto:Gnso-epdp-team at icann.org>
>
> https://mm.icann.org/mailman/listinfo/gnso-epdp-team <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gnso-2Depdp-2Dteam&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=KsnUZFZN_ds3hfDU81KaQh1PouUijCAV1NUDwpIOsAg&e=>
>
> _______________________________________________
>
> By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_policy&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=FwUQq5l0Y2FAOewYgUPeC3ZpkOkUcsYGbDQDGdrn51g&e=>) and the website Terms of Service (https://www.icann.org/privacy/tos <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_tos&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=DIqsoPEEZERBjh2YW7dICqGWkBj7ALzyba1voyOPzMk&e=>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
>
> --
> Volker A. Greimann
> General Counsel and Policy Manager
> *KEY-SYSTEMS GMBH*
>
> T: +49 6894 9396901
> M: +49 6894 9396851
> F: +49 6894 9396851
> W: www.key-systems.net
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.key-2Dsystems.net&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=hwQnHWrq0qIdx6kVhoowbCd4SZ1nSrXYOX7R9KBc0JM&e=>
>
> Key-Systems GmbH is a company registered at the local court of
> Saarbruecken, Germany with the registration no. HR B 18835
> CEO: Alexander Siffrin
>
> Part of the CentralNic Group PLC (LON: CNIC) a company
> registered in England and Wales with company number 8576358.
>
> _______________________________________________
> Gnso-epdp-team mailing list
> Gnso-epdp-team at icann.org <mailto:Gnso-epdp-team at icann.org>
> https://mm.icann.org/mailman/listinfo/gnso-epdp-team
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gnso-2Depdp-2Dteam&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=KsnUZFZN_ds3hfDU81KaQh1PouUijCAV1NUDwpIOsAg&e=>
> _______________________________________________
> By submitting your personal data, you consent to the
> processing of your personal data for purposes of subscribing
> to this mailing list accordance with the ICANN Privacy Policy
> (https://www.icann.org/privacy/policy
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_policy&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=FwUQq5l0Y2FAOewYgUPeC3ZpkOkUcsYGbDQDGdrn51g&e=>)
> and the website Terms of Service
> (https://www.icann.org/privacy/tos
> <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_tos&d=DwMFaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=i8lF_vDhT_peOZsF_kHctAAjfsmIBrNuFvOup8q3LFs&s=DIqsoPEEZERBjh2YW7dICqGWkBj7ALzyba1voyOPzMk&e=>).
> You can visit the Mailman link above to change your membership
> status or configuration, including unsubscribing, setting
> digest-style delivery or disabling delivery altogether (e.g.,
> for a vacation), and so on.
>
>
>
> _______________________________________________
>
> Gnso-epdp-team mailing list
>
> Gnso-epdp-team at icann.org <mailto:Gnso-epdp-team at icann.org>
>
> https://mm.icann.org/mailman/listinfo/gnso-epdp-team <https://urldefense.proofpoint.com/v2/url?u=https-3A__mm.icann.org_mailman_listinfo_gnso-2Depdp-2Dteam&d=DwMGaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=6ugXFDtMSp5TN-tGQMAzXjvDtHOuYWQWQNcAzRH3LdY&s=14PnxLXVFMTIGWWbF7k0KG1crIpW38SedNJjX9-zNn0&e=>
>
> _______________________________________________
>
> By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_policy&d=DwMGaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=6ugXFDtMSp5TN-tGQMAzXjvDtHOuYWQWQNcAzRH3LdY&s=D1dN_llu6Tbkcs62nPs2bv31b8e3lKufIbEiylp3GdI&e=>) and the website Terms of Service (https://www.icann.org/privacy/tos <https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_privacy_tos&d=DwMGaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=6ugXFDtMSp5TN-tGQMAzXjvDtHOuYWQWQNcAzRH3LdY&s=JH0Fkze6xob9fbzReu0Azcu6-Rq2iStP-ZCyB_jFoCo&e=>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
>
> --
> Volker A. Greimann
> General Counsel and Policy Manager
> *KEY-SYSTEMS GMBH*
>
> T: +49 6894 9396901
> M: +49 6894 9396851
> F: +49 6894 9396851
> W: www.key-systems.net
> <https://urldefense.proofpoint.com/v2/url?u=http-3A__www.key-2Dsystems.net&d=DwMGaQ&c=5VD0RTtNlTh3ycd41b3MUw&r=_4XWSt8rUHZPiRG6CoP4Fnk_CCk4p550lffeMi3E1z8&m=6ugXFDtMSp5TN-tGQMAzXjvDtHOuYWQWQNcAzRH3LdY&s=UhiYqnRvRppumnSvfFWK9c32gZOekoZ1T3kbYAo1WAI&e=>
>
> Key-Systems GmbH is a company registered at the local court of
> Saarbruecken, Germany with the registration no. HR B 18835
> CEO: Alexander Siffrin
>
> Part of the CentralNic Group PLC (LON: CNIC) a company registered in
> England and Wales with company number 8576358.
>
>
> _______________________________________________
> Gnso-epdp-team mailing list
> Gnso-epdp-team at icann.org
> https://mm.icann.org/mailman/listinfo/gnso-epdp-team
> _______________________________________________
> By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
--
Volker A. Greimann
General Counsel and Policy Manager
*KEY-SYSTEMS GMBH*
T: +49 6894 9396901
M: +49 6894 9396851
F: +49 6894 9396851
W: www.key-systems.net
Key-Systems GmbH is a company registered at the local court of
Saarbruecken, Germany with the registration no. HR B 18835
CEO: Alexander Siffrin
Part of the CentralNic Group PLC (LON: CNIC) a company registered in
England and Wales with company number 8576358.
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://mm.icann.org/pipermail/gnso-epdp-team/attachments/20190603/0be6a0df/attachment-0001.html>
More information about the Gnso-epdp-team
mailing list