Obviously, according to the European Court of Justice, all information that in combination with other pieces of information could lead to the identification of the data subject is also personal information, so that differentiation is moot. (See: IP-Addresses in Case 582/14 – Patrick Breyer v Germany)

The only scenario where nonpublic information is not public information is when the data cannot lead to the identification of the data subject, but that cannot usually be seen on its face. For example the commonly used role "Domain Manager" could be personal information if someone on that company website is listed as such, the company only has one staff member in that role or other factors and data sources allow the identification or the ability to build a personal profile.

So yes, even legal entities may have used data in their registation data sets that can be considered personal information, which is why contracted parties have argued for no differentiation between entity types. Ultimately, the type is irrelevant, the data used is relevant.

Best,

Volker

Am 09.05.2019 um 16:24 schrieb Hadia Abdelsalam Mokhtar EL miniawi:

Hi All,

 

I would not use the term " disclosure/access to personal information" but would rather use the term " disclosure/access to nonpublic registration data". The reason for this is that by definition, some of the redacted data is not personal information, but was redacted because it was thought that in combination with other pieces of information it could lead to identifying the data subject.

 

Best Regards,

Hadia

 

From: Gnso-epdp-team [mailto:gnso-epdp-team-bounces@icann.org] On Behalf Of Marika Konings
Sent: Wednesday, May 08, 2019 11:39 PM
To: Mueller, Milton L; gnso-epdp-team@icann.org
Subject: Re: [Gnso-epdp-team] [Ext] RE: For your review - Phase 2 Draft Approach

 

Apologies, it looks like the pdf conversion got rid of the ticks. We’ve replaced them with ‘X’ in the attached version.

 

Best regards,

 

Caitlin, Berry and Marika

 

From: "Mueller, Milton L" <milton@gatech.edu>
Date: Wednesday, May 8, 2019 at 15:35
To: Marika Konings <marika.konings@icann.org>, "gnso-epdp-team@icann.org" <gnso-epdp-team@icann.org>
Subject: [Ext] RE: For your review - Phase 2 Draft Approach

 

Hi,

Looks like Janis and staff have been busy!

I have a question about Slide 7. There are no “X’s” or ticks in the columns for WS 1 and WS 2.

So I can’t tell what this means. Are we proposing (I hope) that WS1 meets on Tuesdays and WS2 meets on Thursdays? Or is this still open-ended?

 

--MM

 

From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Marika Konings
Sent: Wednesday, May 8, 2019 2:07 PM
To: gnso-epdp-team@icann.org
Subject: [Gnso-epdp-team] For your review - Phase 2 Draft Approach

 

Sending on behalf of Janis Karklins

 

Dear EPDP Team,

 

Following last week’s meeting, the leadership team and staff support have worked together on developing a draft approach for tackling phase 2. We hope this strikes a balance between the different views expressed and will form the basis for a detailed work plan with concrete milestones and deliverables. You will find attached a couple of slides that outline our current thinking in further detail, but here are some points I want to emphasize:

 

 

I look forward to receiving your feedback and would like to encourage you to focus your input on what, why and how things could or should be done differently, instead of simply saying that something cannot be acceptable or should not be done.

 

Janis Karklins

 

Marika Konings

Vice President, Policy Development Support – GNSO, Internet Corporation for Assigned Names and Numbers (ICANN) 

Email: marika.konings@icann.org  

 

Follow the GNSO via Twitter @ICANN_GNSO

Find out more about the GNSO by taking our interactive courses and visiting the GNSO Newcomer pages

 


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Volker A. Greimann
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