Hi Kurt,
A few comments on the updated Rec 12 language
- I support the use of the phrase “Reasonable Requests for Lawful Disclosure of Non-Public Registration Data.” instead of "Reasonable Access". It is much more precise.
- At the end of the 3rd paragraph it states "Contracted parties will consider each request on its merits with regard to GDPR legal basis". This is reasonable, however it is inconstant with the Temp Spec language quoted in paragraph 1 that limits reasonable access to 6(1)(f). (e.g. "Registrar and Registrar and Registry Operator MUST provide reasonable access to Personal Data in Registration Data to third parties on the basis of a legitimate interests pursued by the third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Registered Name Holder or data subject pursuant to Article 6(1)(f) GDPR") If contracted parties will be responding to "reasonable disclosure" requests for any legal basis we need to ensure existing temp spec language is updated (made consistent)in any future policy implementation created to replace it
- As I mentioned on a past call we have kept the specificity regarding the request but lost specificity regarding the response. Hoping we can find a pragmatic middle ground for the latter here is a suggested solution.