Hi Hadia, Responses in-line:
On Dec 5, 2018, at 1:38 PM, Hadia Abdelsalam Mokhtar EL miniawi <Hadia@tra.gov.eg> wrote:
Sorry a correction to the email that I sent in a rush below
Dear Stephanie,
Thank you and all who have contributed to the EDPB draft letter. However I do not agree with the statement in the first paragraph that says
" ICANN is a global non-governmental non-profit organization responsible for ensuring the stable and secure operation of the Internet's system of unique identifiers, i.e., domain names and IP addresses."
The above statement attempts to define ICANN's mission – which is indeed out of our scope - and strongly contradicts with ICANN's note to the EDPB on May 5 2018 and contradicts with the letter sent on July 5 from EDPB to Goran Marby in which the EDPB acknowledges that ICANN's mandate goes beyond ensuring the stable and secure operation of the Internet's system of unique identifier. To remind you the letter of July 5 from EDPB said
" in its letter of 10 may 2018, ICANN makes several references to ICANN's Bylaws to underline that ICANN's mission with respect to domain names is not limited to ensuring the stable and secure operation of the internet unique identifiers system (technical stability). The EDPB has taken note of ICANN's Bylaws, which require ICANN, in carrying out its mandate …”
The original language seems fine to me. It’s consistent with the bylaws, and if it helps at all, it doesn’t say that ICANN’s mission is limited to anything. It just states that ICANN is responsible for ensuring the stable and secure operation of the Internet’s system of unique identifiers. Surely, this is something that isn’t worth objecting to?
I also do not agree with the statement in the draft letter that says " the ICANN Board adopted a Temporary Specification for gTLD Registration Data (“Temporary Specification”), which is intended to bring the domain name ecosystem into GDPR compliance"
The aforementioned intention of the temporary specification is too broad, the temporary specification is intended to ensure that the Personal Data that is Processed by certain participants in the gTLD domain name ecosystem is in compliance with the GDPR, we are certainly not working on the whole domain name ecosystem nor is it within our mandate.
Agree that the original language is not correct. It would be best to be more accurate and specific on this. We wouldn’t want to convey a wrong impression of what the EPDP Team was chartered to do. Thanks. Amr