I am sometimes amazed at our ability to debate issues where it is not
warranted. We spend a significant amount of time on Tuesday on Tech and
Admin contacts (both voice and a lot in the chat).
Among other things, the principle of data minimization was
sited.
The EDPB letter of 05 July 2018 says:
The EDPB
considers that registrants should in principle not be required to provide
personal data
directly identifying individual employees (or third parties) fulfilling
the administrative or technical
functions on behalf of the registrant. Instead, registrants should be
provided with the option of
providing contact details for persons other than themselves if they wish
to delegate these
functions
·
and
facilitate direct communication with the persons concerned.
It
should
therefore be made clear,
as part of the registration process, that the registrant is free to ( 1)
designate the same person as the
registrant (or its representative) as the administrative or technical
contact; or (2) provide contact
information which does not directly identify the administrative or
technical contact person
concerned (e.g.
admin
@company.com
). For the
avoidance of doubt, the EDPB recommends
explicitly clarifying this within future updates of the Temporary
Specification.
We are told that in one case, 30% of registration done by resellers use
those field for unique data. We know many legal persons do.
If the EDPB is ok with such collection (with appropriate warnings), and
many registrants use the fields, why do we need to re-debate it. Aren't
there enough substantive issues to focus on?
Alan