Hello Everyone,
Over the past couple of weeks there has been a recurring theme in our calls and in some of the side discussions that I have had with some members regarding about how the potential lack of a Data Processing Agreement between ICANN Org and the Contracting Parties might negatively impact our future work and/or recommendations.
Therefore I would like to propose to the group for their consideration the following additional questions that we may want to propose to ICANN Org as we continue our work:
Is ICANN able to access registration data under the GDPR on the basis that it has a legitimate interest in checking the accuracy of the data? Has ICANN ever received or plans to receive legal advice on this particular topic?
Does ICANN believe that the Data Protection Agreement between itself and the Contracted Parties is a necessary legal requirement for requesting and receiving this data, and if so for what legal reason?"
As always I welcome any thoughts and or considerations?
Best regards,
Michael