Alan,

I do understand the contracted parties who push back for at least 2 reasons:

the mobility of registrants
the complexity of managing 2 kind of treatment

I though it was said in the beginning that the contracted parties should remain free to apply universally or only for the European subjects. This is in my opinion the best choice.

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Tijani BEN JEMAA

Executive Director

Mediterranean Federation of Internet Associations (FMAI)

Phone: +216 98 330 114

+216 52 385 114

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Le 30 oct. 2018 à 02:32, Alan Greenberg <alan.greenberg@mcgill.ca> a écrit :

GDPR is applicable to residents of the EU by companies resident there
and worldwide.

One of the issues is whether contracted parties should be allowed or
required to distinguish between those who are resident there and elsewhere.

There is agreement that such distinction should be allowed, but EPDP
is divided on whether it should be required. The GAC/BC/IPC want to
see the distinction made, and at least one very large contracted
party does already make the distinction. Other contracted parties are
pushing back VERY strongly saying that there is virtually no way that
the can or are willing to make the distinction.

The current (confusing) state of the working document is attached.

Which side should ALAC come down on?

- Restrict application to those to whom GDPR applies?
- Apply universally ignoring residence?

As usual, quick replies requested.

Alan<RySG revisions Small Team #2 Geographic - updated.pdf>_______________________________________________
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