[Gnso-epdp-team] Rec 4 suggested text

Volker Greimann vgreimann at key-systems.net
Thu Aug 12 12:22:01 UTC 2021

Hi Chris,

I do not see how this statement interpreting the GDPR would rise to the
level of a recommendation. Essentially, only the latter part is needed:
"when processing legal persons’ data, safeguards should be put in place to
ensure that personally identifying data about a natural person is not
disclosed within data marked as a legal person."

Volker A. Greimann
General Counsel and Policy Manager

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On Thu, Aug 12, 2021 at 12:57 PM LEWIS-EVANS, Christopher via
Gnso-epdp-team <gnso-epdp-team at icann.org> wrote:

> Suggested text for recommendation 4 as discussed on the last call, believe
> it should go between current 2 and 3.
> Thanks
> Chris
> The GDPR protects natural persons in relation to the processing of their
> personal data.  "It does not cover the processing of personal data which
> concerns legal persons and in particular undertakings established as legal
> persons, including the name and the form of the legal person and the
> contact details of the legal person." This allows for disclosure of legal
> persons’ data because it is outside the remit of GDPR.  Nevertheless, when
> processing legal persons’ data, safeguards should be put in place to ensure
> that personally identifying data about a natural person is not disclosed
> within data marked as a legal person.
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