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
- What is research within the ICANN
context? And does it have scientific purposes?
- 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?
- Art 89 and relevant recitals in scope
due to whatever research is within the ICANN context?
- 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