Hello All, For Recommendation 1 Purpose 1, the RrSG has the following comments: * Rename this to: Further Processing of Data. * Within the ICANN context we want to process data collected for a different purpose to be further processed for research purposes o What is research within the ICANN context? And does it have scientific purposes? o Is the ARS Reporting system research, or as the name indicates a reporting system that flags possible incorrect data? And is this not already in scope of the GDPR? o Art 89 and relevant recitals in scope due to whatever research is within the ICANN context? o Depending on the research do Art 17 and 21 apply? * *In short with the above in mind, what does the WG think is research and does it require processing of personal data?* -- Sarah Wyld Domains Product Team Tucows +1.416 535 0123 Ext. 1392