All (but esp. Alan & Hadia),

I have noted the ongoing discussion of “access” vs. “disclosure” on the EPDP mailing list, most recently involving Alan Greenberg, M3 (Mighty Milton Mueller) and Alan Woods.  Two suggestions if Alan G decides to reply:

1.  The EC, in their letter (which many are parsing closely and believe to be of great import) refers (approvingly) to the “unified access model.”  If “access” is good enough for the EC, it’s good enough for us. This can be pointed out. The EC also implored the EPDP to focus and get its work done quickly.  Arguments like this are the opposite of that.

2.  If the EPDP wants to maintain a distinction between access for data subjects and for everybody else, it can use the terms “data subject access” and “third party access.”  The UAM can become the UTPAM (which is also a variant spelling for a delicious Indian dosa-like dish (but thicker and typically served flat with toppings)).  Everyone should be happy at this point.

Greg