Hi Amy, While I think that a processing agreement in some shape or form will be required, also depending on the legal review I do not believe this IRT should wade into section 4. My personal opinion is that this section is somewhat "muddy." And I am very diplomatic here. But casting my personal opinion aside here, this section, if I am correct, is part of the ePDP scope. So it would be counterproductive and perhaps create a delay for a WG that needs to operate rapidly. In addition to this, how would this IRT go through this section and come up with a position that is data protection compliant? I think it would make more sense we focus on the processing itself, and exclude section 4. The processing itself will be complicated enough in terms of setting up an agreement that is data protection compliant. Best, Theo On 12-7-2018 21:13, Amy Bivins wrote:
We will not have a PP IRT meeting on Tuesday, 17 July. Our next meeting is scheduled for Tuesday, 24 July.
The Legal review of the current PPAA draft is not yet complete. However, I do have an update on the GDPR-related work.
We believe that we will likely need to add data processing provisions in the PP materials—potentially in the policy document. We are planning to begin drafting this, for discussion with you, using Section 4 of the Temporary Specification <https://www.icann.org/resources/pages/gtld-registration-data-specs-en/#4> as a model for adaptation. If you have other ideas or recommendations for this initial drafting exercise, please let us know. We can discuss this at our next meeting. A data processing addendum may also be needed for the PPAA.