[IRT.RegDataPolicy] Rec26 IRT comments closing - DPA 3rd parties

[Anderson, Marc]

Dennis, IPT and IRT,



I have essentially the same feedback for Rec #26 as I did for Rec #22.  I agree with closing out Rec #26 and that no new consensus policy is needed.  This is a recommendation for ICANN org to enter into required data protection agreements with 3rd parties (such as escrow and EBERO providers).



Also like my Rec #22 comments, I don’t think this should be bundled with Rec #19.  I’ll note the same email thread with Sarah and Dennis which seems to support the position that data processing agreements among contracted parties should be treated separately from those involving 3rd parties:


https://mm.icann.org/pipermail/irt.regdatapolicy/2019-September/000157.html

https://mm.icann.org/pipermail/irt.regdatapolicy/2019-September/000174.html



thanks,
Marc







From: IRT.RegDataPolicy <irt.regdatapolicy-bounces at icann.org> On Behalf Of Dennis Chang
Sent: Monday, October 28, 2019 3:53 PM
To: irt.regdatapolicy at icann.org
Subject: [EXTERNAL] [IRT.RegDataPolicy] Rec26 IRT comments closing - DPA 3rd parties



Call to close IRT comments on recommendation #26 analysis regarding DPA for 3rd parties

64

IRT review closing Recommendation #26 Analysis - DPA 3rd parties<https://docs.google.com/document/d/1pHDZQEugoJBlbCl0mUPNjuliCce7I9T5v_M5aTQ-PCU/edit>

20191101





--

Kind Regards,

Dennis S. Chang

GDD Programs Director

Phone: +1 213 293 7889

Sykpe: dennisSchang

www.icann.org<http://www.icann.org> One World – One Internet

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