PP IRT Action Items This Week
Dear Colleagues, ICANN org is continuing to review your feedback on the PPAA draft, and I hope to have an update this week as to your specific feedback on the data processing provisions. In the interim, please provide any feedback you have on the following no later than your end of day on Friday, 21 Sept: 1. In Specification 3, do you have any issue with incorporating a definition of action/actioned? We have attempted to clarify the term in Section 3.2.3 (p. 52) to state "action, in accordance with Sections 4.1 and 4.2..." but we believe this could be made more clear by explicitly defining this term. For example, we could add a definition that states that action means "to disclose the Requested Information, to refuse in writing to disclose the Requested Information, and/or to inform the LEA Requester that more time is required to respond to the request." 2. Should we add a new explicit basis for a Provider to reasonably refuse to disclose Requested Information in Specification 3, Section 4.1, where the Provider has a basis for reasonably believing that such Disclosure would violate relevant data protection law? 3. In Specification 4 (p. 62)-should this section title be updated since it doesn't specifically address how to resolve disputes? In addition, does the IRT wish to review the meaning and intent of this section in light of data subject rights in the GDPR, and its relevance to resolving disputes concerning data protection matters? Best, Amy Amy E. Bivins Registrar Services and Engagement Senior Manager Registrar Services and Industry Relations Internet Corporation for Assigned Names and Numbers (ICANN) Direct: +1 (202) 249-7551 Fax: +1 (202) 789-0104 Email: amy.bivins@icann.org<mailto:amy.bivins@icann.org> www.icann.org<http://www.icann.org>
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Amy Bivins