Bastiaan, thanks for your thoughts. Unfortunately, what you describe as the phase 1 process is not quite how it happened. I cannot elaborate right now but will have a few hours on a train shortly and will do so then. Alan -- Sent from my mobile. Please excuse brevity and typos. On March 29, 2019 12:58:45 AM GMT+09:00, Bastiaan Goslings <bastiaan.goslings@ams-ix.net> wrote: Hi all, With regard to https://community.icann.org/pages/viewpage.action?pageId=105383443 I expressed earlier that I do not think that contracted parties should be mandated to differentiate between registrants on a geographic basis. See rec#16 of the final phase 1 EPDP-report. I was on the CPWG call yesterday, but considering the time constraint I felt it was not the place to touch on the specific issue of (non) geographical distinction again as it is not clear to me yet whether the penholders indeed want to raise this a concern in the advice. (Btw Even if geographical distinction is mandated, according to rec#10 contracted can still choose to redact data even if the GDPR is not applicable. But that is beside the point here) Besides me potentially disagreeing with the (part of the) content of a (proposed) advice, I am slightly concerned with regard to the process and how it might be perceived by others. Even when only we stress the importance of a Unified Access Model (UAM) and that we want a clear distinction to be made by contracted parties between natural and legal persons, both of which I can agree with, these topics are explicitly to be covered by phase 2. The UAM model is a no brainer and meant to be one of the main end-products of phase 2. And Rec# 17 in the phase 1 end-report is very clear on the natural vs legal distinction that needs to be resolved. Also: - We had plenty of opportunities to raise our concerns in the EPDP deliberations themselves, I’m sure Hadia and Alan did a great job; - Our concerns are included in our statement in the phase 1 final report that the board will take note of; - We reiterated these in the recently shared GAC-ALAC statement And the final report of phase 1 says on page 148, Annex 'Note the BC / IPC minority statement. All other groups support the Final Report.’ I am sure all groups had to make compromises to reach consensus and support the report. I do not think it would look good if we would be perceived, with an advice to the board, as attempting to open up the report and cherry pick recommendations we like and ask the board not to follow up on those we disagree with. thanks, Bastiaan *** Please note that this communication is confidential, legally privileged, and subject to a disclaimer: https://www.ams-ix.net/ams/email-disclaimer ***