Jan. 6, 2019
7:51 p.m.
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