Hello Laureen, I read the GAC’s input with interest. Can you help me understand what you mean by: We recommend that contracted parties develop mechanisms that ensure a reliable determination of natural or legal person status for registrants going forward (post- implementation of new contract specifications) and for their legacy registrants and recognize that these procedures will likely require a phased approach that allows more time for contracted parties to deal with their legacy customers. I cannot imagine how this could be implemented in a compliant fashion and would appreciate if the GAC could share its vision on how this could be operationalized. Also, I think we agree that GDPR is about protection data of natural persons. But I had also hoped our group had reached a common understanding that there are instances where legal entities data can be PII. Does the GAC not acknowledge this? At least the position - as enshrined in the document you shared - does not reflect that. Thank you and kind regards, Thomas
Am 02.11.2018 um 20:34 schrieb Kapin, Laureen via Gnso-epdp-team <gnso-epdp-team@icann.org>:
Please see the attached input from the GAC.
Laureen Kapin Counsel for International Consumer Protection Office of International Affairs Federal Trade Commission (202) 326-3237 <tel:(202)%20326-3237> lkapin@ftc.gov <mailto:lkapin@ftc.gov>
From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org <mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Marika Konings Sent: Friday, November 02, 2018 9:55 AM To: gnso-epdp-team@icann.org <mailto:gnso-epdp-team@icann.org> Subject: [Gnso-epdp-team] Reminder - Action items due today, Friday 2 November
Dear All,
As a reminder, the following action items are due today, Friday 2 November COB, in order to allow the leadership team and staff to plan the meetings and agenda’s going forward:
Each group (SG/C/AC) to review the responsible parties overview for all purposes and identify which designations need to be further considered. See https://docs.google.com/document/d/1-rdfchOwpANFVKOtnM_9bPp-zT4JAvTN8dJqebdi... <https://docs.google.com/document/d/1-rdfchOwpANFVKOtnM_9bPp-zT4JAvTN8dJqebdi...>. Each group (SG/C/AC) to review latest versions of data elements workbooks and flag any issues that need to be reviewed prior to publication of Initial Report. See https://community.icann.org/x/5AC8BQ <https://community.icann.org/x/5AC8BQ>. Each group (SG/C/AC) to express the group's views and/or proposed edits on small team #1 responses to charter questions and preliminary recommendations with the mailing list (see original version and input received to date attached). Each group (SG/C/AC) to express the group's views and/or proposed edits on the revised responses of the small team #2 charter question responses with the mailing list (see original version and input received to date attached).
Thanks,
Caitlin, Berry and Marika
Marika Konings Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN) Email: marika.konings@icann.org <mailto:marika.konings@icann.org>
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