On rereading my reply, I find I may not have been sufficiently precise. The issue of who the controller is or who the controllers are is actually of great importance to users, as it ultimately implies who has liability under GDPR and therefore who may or may not take risks {and therefore how "open" the RDS ends up). But it is the answer that has implications. Although I (and we) may have our "wish list" as to how we want it to come out, we do not have a lot to add to the deliberations. Alan At 06/01/2019 03:46 PM, Holly Raiche wrote:
Thanks Alan
When I read the questions, I was very unsure as to what I would thing, but more importantly, if it is an issue for users.
This confirms my thoughts so thanks for the explanation
Holly
On Jan 7, 2019, at 6:51 AM, Alan Greenberg <alan.greenberg@mcgill.ca> wrote:
There have been questions asked as to why we omitted replying to certain questions in the EPDP response (in particular Recs 13, 14 and 21).
This was not an error, but intentional. The Recs were in relation to Data Processing roles and responsibilities, the classification of who is the "controller" under GDPR, and what formal agreements need to be in place between the various contracted parties and ICANN. The answer is that we did not think that these issues had specific relevancy to Individual users nor did we have the legal expertise to contribute strong arguments.
Alan
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