PP IRT status update; no meeting Tuesday
Dear Colleagues, 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. In addition, we are also considering how to address data processing in data escrow agreements. I should have more to share on that with you by our next meeting. 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>
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.
Thanks for this information Amy. Quick question, what does the addition of the data processing actually entail in terms of process and timing? ________________________________ From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Sent: Thursday, July 12, 2018 3:13 PM To: gdd-gnso-ppsai-impl@icann.org Subject: [Gdd-gnso-ppsai-impl] PP IRT status update; no meeting Tuesday Dear Colleagues, 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. In addition, we are also considering how to address data processing in data escrow agreements. I should have more to share on that with you by our next meeting. 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>
Thanks, Ashley. In terms of process-ICANN org will propose language to incorporate into the existing materials for IRT discussion and feedback. The timing will depend on how long it takes to draft and discuss the language. In terms of drafting, if we stick closely to the existing language in the Temp Spec as a starting point, the initial drafting should be relatively quick-I'd expect we would have material to discuss ready in a matter of weeks; taking a different approach would likely take longer. This is also against the backdrop of the pending GDPR review-if additional items for discussion are identified there, that might extend this process. I hope this helps! Please let me know, Ashley or anyone else, if you have further questions or feedback. 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> From: Gdd-gnso-ppsai-impl [mailto:gdd-gnso-ppsai-impl-bounces@icann.org] On Behalf Of Heineman, Ashley Sent: Friday, July 13, 2018 2:26 PM To: gdd-gnso-ppsai-impl@icann.org Subject: Re: [Gdd-gnso-ppsai-impl] PP IRT status update; no meeting Tuesday Thanks for this information Amy. Quick question, what does the addition of the data processing actually entail in terms of process and timing? ________________________________ From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org<mailto:gdd-gnso-ppsai-impl-bounces@icann.org>> on behalf of Amy Bivins <amy.bivins@icann.org<mailto:amy.bivins@icann.org>> Sent: Thursday, July 12, 2018 3:13 PM To: gdd-gnso-ppsai-impl@icann.org<mailto:gdd-gnso-ppsai-impl@icann.org> Subject: [Gdd-gnso-ppsai-impl] PP IRT status update; no meeting Tuesday Dear Colleagues, 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. In addition, we are also considering how to address data processing in data escrow agreements. I should have more to share on that with you by our next meeting. 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>
participants (3)
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Amy Bivins -
Heineman, Ashley -
theo geurts