Suggested Redlines to ensure lawfulness of processing is not limited to Article 6.1.f and thus subject to a balancing test. Section 4.4 However, such Processing must be in a manner that complies with the GDPR, including on the basis of a specific identified purpose for such Processing. Accordingly, Personal Data included in Registration Data may be Processed on the lawful bases as scoped in GDPR Article 2 or as enumerated in GDPR Article 6.1, and for at least the following legitimate purposes: Comments from Kavouss In order to enable the reader to agree with the proposed changes, the referred Articles of GPDR should be hyperlinked.However, therte are two WAYS: One WAY would be that the Text of Temp .Specification, which at later date become definitive specification should be self contained and self sufficient in order to avois D the readers to refer to other sources as well as to avoid misinterpretation of several terms and associated qulaifiers mentioned in those Articles. The Second way would be to make the text as concise and short as possible but cross reference to othe Articles of GPDR with the risk of unintended misiterpretations and lack of definitions of terms and qualifiers used in those Articles Appendix A.4.1 *4. Access to Non-Public Registration Data * 4.1. Registrar and Registry Operator MUST provide reasonable access to Personal Data in Registration Data to third parties on the lawful bases as scoped in GDPR Article 2 and as enumerated in GDPR Article 6.1. See above comments Appendix C.2 *2. Lawfulness of Processing * For Personal Data Processed in connection with the Registration Data Directory Services, such Processing will take place on the lawful bases as scoped in GDPR Article 2 and as enumerated in GDPR Article 6.1, For other Personal Data collected for other purposes, such Personal Data SHALL NOT be Processed unless a legal basis specified under Article 6(1) GDPR applies. See above comments On Mon, Sep 3, 2018 at 10:10 PM Alex Deacon <alex@colevalleyconsulting.com> wrote:
All,
On Thursday I took an action to propose updates that ensures lawfulness of processing is not limited to Article 6.1.f (and thus subject to a balancing test).
I've attached a proposed redline for discussion. You will note it addresses Section 4.4 and Appendix C.2 (per my action) and for completeness I also updated Appendix A.4.1 for consistency.
Regards, Alex
-- ___________ *Alex Deacon* Cole Valley Consulting alex@colevalleyconsulting.com +1.415.488.6009
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