Re: [Gdd-gnso-ppsai-impl] PP IRT status update; no meeting Tuesday
Hi Amy, I’m a little unclear as to how we intend the Privacy/Proxy Accreditation Agreement to dictate the terms for data processing, as this is something that will need to be agreed to between the Registrar and the Privacy/Proxy Provider, unless the intent is to create a standard set of terms that are included as a model, but capable of being modified or supplemented by the Registrar? If so, then perhaps this should be handled similar to that of the recent RRA Amendment, which adds appropriate data processing terms to the RAA (via the form and process outlined here https://www.icann.org/en/system/files/files/rra-amendment-terms-temp-spec-02...). It would differ in that these terms could be directly incorporated into the P/P Accreditation Agreement, rather than via an amendment as in the case of the previously executed RAAs, and the form and substance would need to be modified for these particular purposes, but the concept of “model clauses” might be viable. In any event, we do not believe use of Section 4 of the Temp Specification is adequate or appropriate for these purposes. Sara sara bockey sr. policy manager | GoDaddy™ sbockey@godaddy.com<mailto:sbockey@godaddy.com> 480-366-3616 skype: sbockey This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments. From: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> Reply-To: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> Date: Thursday, July 12, 2018 at 12:13 PM To: "gdd-gnso-ppsai-impl@icann.org" <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>
I Agree with Sara on several levels here. But I think we need to know what kinda of processing agreement we are talking here before we go into the weeds. Is the agreement meant for ICANN as an organization, or are we going to create a language for third party privacy providers (just an example), which will be a real challenge? Theo Sara Bockey schreef op 2018-07-17 10:12 PM:
Hi Amy,
I’m a little unclear as to how we intend the Privacy/Proxy Accreditation Agreement to dictate the terms for data processing, as this is something that will need to be agreed to between the Registrar and the Privacy/Proxy Provider, unless the intent is to create a standard set of terms that are included as a model, but capable of being modified or supplemented by the Registrar? If so, then perhaps this should be handled similar to that of the recent RRA Amendment, which adds appropriate data processing terms to the RAA (via the form and process outlined here https://www.icann.org/en/system/files/files/rra-amendment-terms-temp-spec-02... [1]). It would differ in that these terms could be directly incorporated into the P/P Accreditation Agreement, rather than via an amendment as in the case of the previously executed RAAs, and the form and substance would need to be modified for these particular purposes, but the concept of “model clauses” might be viable.
In any event, we do not believe use of Section 4 of the Temp Specification is adequate or appropriate for these purposes.
Sara
SARA BOCKEY
SR. POLICY MANAGER | GODADDY™
SBOCKEY@GODADDY.COM 480-366-3616
SKYPE: SBOCKEY
_ _
_This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments._
FROM: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> REPLY-TO: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> DATE: Thursday, July 12, 2018 at 12:13 PM TO: "gdd-gnso-ppsai-impl@icann.org" <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 [2] 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
www.icann.org [3]
Links: ------ [1] https://www.icann.org/en/system/files/files/rra-amendment-terms-temp-spec-02... [2] https://www.icann.org/resources/pages/gtld-registration-data-specs-en/#4 [3] http://www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Thanks, Theo and Sara, I will take these questions and comments back to the legal team for discussion, and hope to have more to share next week. Sent from my iPhone
On Jul 18, 2018, at 4:49 AM, gtheo <gtheo@xs4all.nl> wrote:
I Agree with Sara on several levels here. But I think we need to know what kinda of processing agreement we are talking here before we go into the weeds. Is the agreement meant for ICANN as an organization, or are we going to create a language for third party privacy providers (just an example), which will be a real challenge?
Theo
Sara Bockey schreef op 2018-07-17 10:12 PM:
Hi Amy, I’m a little unclear as to how we intend the Privacy/Proxy Accreditation Agreement to dictate the terms for data processing, as this is something that will need to be agreed to between the Registrar and the Privacy/Proxy Provider, unless the intent is to create a standard set of terms that are included as a model, but capable of being modified or supplemented by the Registrar? If so, then perhaps this should be handled similar to that of the recent RRA Amendment, which adds appropriate data processing terms to the RAA (via the form and process outlined here https://www.icann.org/en/system/files/files/rra-amendment-terms-temp-spec-02... [1]). It would differ in that these terms could be directly incorporated into the P/P Accreditation Agreement, rather than via an amendment as in the case of the previously executed RAAs, and the form and substance would need to be modified for these particular purposes, but the concept of “model clauses” might be viable. In any event, we do not believe use of Section 4 of the Temp Specification is adequate or appropriate for these purposes. Sara SARA BOCKEY SR. POLICY MANAGER | GODADDY™ SBOCKEY@GODADDY.COM 480-366-3616 SKYPE: SBOCKEY _ _ _This email message and any attachments hereto is intended for use only by the addressee(s) named herein and may contain confidential information. If you have received this email in error, please immediately notify the sender and permanently delete the original and any copy of this message and its attachments._ FROM: Gdd-gnso-ppsai-impl <gdd-gnso-ppsai-impl-bounces@icann.org> on behalf of Amy Bivins <amy.bivins@icann.org> REPLY-TO: "gdd-gnso-ppsai-impl@icann.org" <gdd-gnso-ppsai-impl@icann.org> DATE: Thursday, July 12, 2018 at 12:13 PM TO: "gdd-gnso-ppsai-impl@icann.org" <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 [2] 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 www.icann.org [3] Links: ------ [1] https://www.icann.org/en/system/files/files/rra-amendment-terms-temp-spec-02... [2] https://www.icann.org/resources/pages/gtld-registration-data-specs-en/#4 [3] http://www.icann.org _______________________________________________ Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
Gdd-gnso-ppsai-impl mailing list Gdd-gnso-ppsai-impl@icann.org https://mm.icann.org/mailman/listinfo/gdd-gnso-ppsai-impl
participants (3)
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Amy Bivins -
gtheo -
Sara Bockey