Hello Farzaneh, all,
That point has been made by the Art 29 group in its letter of April 11, 2018. I quote:

"Moreover, it notes that the purposes must be defined in a comprehensive and exhaustive manner. Use of the word “include” suggests that not all purposes are made explicit, which would also be incompatible with article 5(1)b GDPR."

So we should remove the „including, but not limited to“ and those who want things added to the list should speak up. 

An easy fix. I support the other edits.

Best,
Thomas 


Am 06.09.2018 um 05:24 schrieb farzaneh badii <farzaneh.badii@gmail.com>:

Thanks James. I think these edits are good (concurring with Milton and Stephanie on the suggestions as well) But  legitimate  purposes cannot be open ended, therefore in my opinion you cannot have "including but not limited to" in 4.4.8.

we can discuss tomorrow. 

On Wed, Sep 5, 2018 at 10:32 PM James M. Bladel <jbladel@godaddy.com> wrote:
Thank you, Stephanie. Let’s discuss on the next call, but I think our key point is that risk/exposure cannot be decoupled from some degree of judgement. 


-------------
James Bladel
GoDaddy
From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> on behalf of Stephanie Perrin <stephanie.perrin@mail.utoronto.ca>
Sent: Wednesday, September 5, 2018 5:37:42 PM
To: gnso-epdp-team@icann.org
Subject: Re: [Gnso-epdp-team] RrSG edits -- Section 4.4
 

I think these are good edits.  One small point in the last part dealing with non-binding arbitration....I would suggest that you should say "the registrar's interpretation of the law takes precedence", as each side will inevitably have its own interpretation of the law, but only one side is going to get the fine....

Stephanie Perrin

On 2018-09-05 19:42, James M. Bladel wrote:

ePDP Team –

 

In preparation for tomorrow’s call, please find attached a redline PDF of our edits to Section 4.4 of the Temp Spec, along with a slide/PDF with “clean” language for Kurt & Staff. Matt, Theo and I will walk through these edits, along with our rationale.

 

Look forward to our discussion tomorrow.

 

Thanks—


J.

 

-------------

James Bladel

GoDaddy

 

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