[Gnso-epdp-team] [EXTERNAL] Re: On the proposed guidance

ICANN becky.burr at board.icann.org
Wed Apr 14 20:31:24 UTC 2021

Are we/is the plenary discussing a requirement that CPs make an affirmative effort to dissuade legal persons from submitting personal data , eg encourage them to use email alias for tech contact?  If so, then an initial distinction would be necessary. But isn’t that a policy question?

 As I said, I do not have an opinion as to whether NIS2 would permit making non personal data publicly accessible via an SSAD request.  

Becky Burr * Sent from my iPad

> On Apr 14, 2021, at 3:34 PM, Mark Svancarek (CELA) <marksv at microsoft.com> wrote:
> below.
> Finally, I think there is a meaningful distinction between what Melina is advocating (first determine if the person is legal, then look for the edge case where a legal person has submitted personal data despite being instructed not to do so) and what I think Volker is advocating (disregard legal status entirely and make no effort to ensure that legal entities submit only non-personal data).  The intent of these are different and the outcomes will certainly be different.  Given that Melina’s
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