[Gnso-epdp-team] Requestor Purpose - Rec 7

Thomas Rickert (eco) epdp at gdpr.ninja
Tue Jul 28 20:01:23 UTC 2020


Hi all,
Thanks for making this suggestion. It does seem to raise questions and I am afraid I also have some. 

The reference to 
> 
> obligations applicable to regulated entities.
>  

Including the footnote is very broad and maybe too unspecific to be a permissible purpose. We have been advised before that enumerations with „including“, „such as“ etc don’t work. In addition to that the NIS Directive is not a regulation as GDPR so that national implementation varies quite significantly and we might not offer clarity with the example, but confusion. 

Best,
Thomas
========
PS - Sent from my cell. Please excuse typos and brevity.

> Am 27.07.2020 um 17:54 schrieb Crossman, Matthew via Gnso-epdp-team <gnso-epdp-team at icann.org>:
> 
> 
> Hi team,
>  
> As an update, Margie, Brian, and I worked on a compromise for the Rec 7 language on Requestor Purposes. We agreed on the following edit to 7.1(a):
>  
> 7.1(a)
>  
> Requestors MUST submit data disclosure requests for specific purposes such as but not limited to: but not limited to: (i) criminal law enforcement, national or public security, (ii) non law enforcement investigations and civil claims, including, intellectual property infringement and UDRP and URS claims, (iii) consumer protection, abuse prevention, and network security, and (iv) obligations applicable to regulated entities.[1] Requestors MAY also submit data verification requests on the basis of Registered Name Holder (RNH) consent that has been obtained by the Requestor (and is at the sole responsibility of that Requestor), for example to validate the RNH’s claim of ownership of a domain name registration, or contract with the Requestor.
>  
> (Footnote below)
> 1  For example, the  EU Directive on security of network and information systems (known as the NIS Directive) imposes specific obligations on Digital Service Providers and Operators of Essential Services.
>  
> With these changes this is no longer a CLW item for the RySG. Let us know if this new language causes any concern for other groups.
>  
> Thanks,
> Matt
>  
>  
> Matthew Crossman | Amazon 
> Corporate Counsel gTLD Registry, IP
> P: 206-266-1103 | C: 530-574-2956
> Email: mmcross at amazon.com
>  
> 
> [1] This approach is very similar to the business model ARSI had previously discussed with the Author Central Pro teams for the .AUTHOR TLD.
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