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
 
From: Gnso-epdp-team <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
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-dM/edit.
  • 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.
  • 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) 
 
Follow the GNSO via Twitter @ICANN_GNSO
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