[Gnso-epdp-team] Points of Order

Alan Greenberg alan.greenberg at mcgill.ca
Wed Apr 14 23:35:53 UTC 2021

I would like to raise two points of order.

Although my preference is for the PDP to generate consensus policy on 
the Legal/Natural issue, I understand that ultimately that may not be 
possible. That being said:

1. There have been recent discussions that we should not be creating 
advice on whether a registrant is a legal or natural person, but 
rather whether the data items contain personal information. The 
wording from the EPDP Charter is "Should Contracted Parties be 
allowed or required to treat legal and natural persons differently, 
and what mechanism is needed to ensure reliable determination of 
status?" If there is a need to consider individual data items, that 
is a secondary issue, but we need to stick to the charter terms.

2. The Key Metrics Considerations part of the EPDP Charter requires 
the we ensure that we will have metrics to determine the success of 
our recommendations. As such, if we decide that we will not issue 
policy recommendation on the legal/natural issue, but rather only 
guidance, we must also include a policy requirement that contracted 
parties report on whether or not they are actually following the 
guidance. If we do not do that, there is no way to measure our 
ultimate success.


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