Hi Marika- 

Attached please find the IPC’s input on the action items due yesterday. We apologize for the delay, we have all been working very hard on this output post the ICANN meeting and needed to circulate and get input from our constituents.

Action Item #2 -- Small Team #1 Legal vs. Natural

It is the IPC's position that it is important and feasible for contracted parties to differentiate between legal and natural persons. We believe that this distinction is supported and encouraged by the construct of the GDPR and that is valuable for all parties in the practical application of the law as it relates to WHOIS and the DNS framework and ecosystem.

The IPC submits the attached redline with further output and clarification for consideration by the team.  

Action Item #3 - Small Team #2 Geographic Distinction

See attached redline for consideration.  

Action Item #5 - Processing Activities and Responsible Parties

The IPC requests additional time to review this document.   Any comments we may have will be included in our comments to the Purpose Workbooks due November 5th. 

Sincerely,

Diane, Alex and Brian

Diane Plaut

General Counsel and Privacy Officer