Mark,

Basically, you have confused all “cases in which the data controller should disclose” with “cases where disclosure should be automatic merely by making a request”

Let me remind you that “automatic” means _no awareness_ and _no possibility of intervention_ by the contracted party holding the data.

They guaranteed tunnels into the CP’s data.

I would agree that in most of the cases you cite the CP probably should make a disclosure decision, and almost certainly would if the conditions were right. But they still need to have oversight over whether those conditions are met, and that prevents full automation.

From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Mark Svancarek (CELA) via Gnso-epdp-team
Sent: Monday, January 27, 2020 4:17 PM
To: gnso-epdp-team@ICANN.org
Subject: [Gnso-epdp-team] SSAD Use Cases which are automatable

Feedback requested.