Dear team, I have not canvassed my team on this, but in the interests of not delaying, I do not agree that this is an error in need of rectification. This original text and use of the term 'disclosure' in this paragraph, was, I believe, actually quite intentional. As we have discussed, at length, on numerous occasions, publication is a subset of disclosure. Your edit, although technically true, only has the effect of further limiting the guidance to that particular subset of a much broader concept that is being captured here,likely further eroding the utility of the guidance. Specific subsets of disclosure are teased out in the relevant proceeding elements of the guidance (e.g. publication as a disclosure is contemplated in both ss.2 & ss 5). Leaving this as 'disclosure' does not exclude the concept of publication in the remit of the guidance. The change to 'publication', I fear, would necessitate further discussion and I neither believe this to be necessary nor would I advocate for such change at this stage. Warmest regards, Alan [image: Donuts Inc.] <http://donuts.domains/> Alan Woods Senior Manager, Compliance & Policy, Donuts Inc. ------------------------------ Donuts Ground Floor Le Pole House Ship Street Great Dublin 8 <https://www.facebook.com/donutstlds> <https://twitter.com/DonutsInc> <https://www.linkedin.com/company/donuts-inc> Please NOTE: This electronic message, including any attachments, may include privileged, confidential and/or inside information owned by Donuts Inc. . Any distribution or use of this communication by anyone other than the intended recipient(s) is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system. Thank you. On Thu, Sep 2, 2021 at 3:50 AM Mark Svancarek (CELA) via Gnso-epdp-team < gnso-epdp-team@icann.org> wrote:
Hi, in reviewing the current text, I’ve discovered an error in line 156. I’ve included the surrounding text for context.
Lines
Current Text
Corrected Text
152 - 156
The GDPR protects natural persons in relation to the processing of their personal data. The GDPR does not cover the processing of personal data which concerns legal persons and in particular undertakings established as legal persons, including the name and the form of the legal person and the contact details of the legal person[Recital 14, GDPR]
The GDPR protects natural persons in relation to the processing of their personal data. The GDPR does not cover the processing of personal data which concerns legal persons and in particular undertakings established as legal persons, including the name and the form of the legal person and the contact details of the legal person[Recital 14, GDPR]
156 - 160
This generally allows for *disclosure* of legal persons’ data because it is outside the remit of GDPR; however, when processing legal persons’ data, Contracted Parties should put safeguards in place to ensure that personally identifying data about a natural person is not disclosed within data marked as a legal person, as this is an example of information that *is *within the scope of GDPR.
This generally allows for *publication* of legal persons’ data because it is outside the remit of GDPR; however, when processing legal persons’ data, Contracted Parties should put safeguards in place to ensure that personally identifying data about a natural person is not disclosed within data marked as a legal person, as this is an example of information that *is *within the scope of GDPR.
160 - 162
For more information on this distinction, please refer to the *letter *from the European Data Protection Board, beginning on p. 4.
For more information on this distinction, please refer to the *letter *from the European Data Protection Board, beginning on p. 4.
Thanks in advance for fixing this.
*Mark Svancarek*
Principal Program Manager, Corporate Standards Group
Privacy & Regulatory Affairs
Microsoft
marksv@microsoft.com
*www.linkedin.com/in/marksv <http://www.linkedin.com/in/marksv>*
T: [+1] 425-706-2773
_______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org https://mm.icann.org/mailman/listinfo/gnso-epdp-team _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy) and the website Terms of Service (https://www.icann.org/privacy/tos). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on.
