All,

Thomas and I developed proposed revised Rec. 21 language.  I posted it in chat, but copy it below for convenience:

Rec. 21:  The EPDP Team recommends that ICANN Org enters into the required agreements such as a Data Processing Agreement (GDPR Art. 28) or Joint Controller Agreement (Art. 26), as appropriate, with the non-Contracted Party entities involved in registration data processing such as data escrow providers and EBERO providers. These agreements are expected to set out the relationship obligations and instructions for data processing between the different parties.

Kristina Rosette

Senior Corporate Counsel, IP – Domains

rosettek@amazon.com | 703.407.1354