Response from Alan Greenberg 

Holly

I'm not sure who in addition to Hadia has main EPDP list posting rights, but please ensure that this comment is posted prior to the Wed. meeting.

I see two problems with the proposal.

1. It still does not set an expectation that although SOME requests may take the specified limit, not all should. Nor does it seem to imply that the Contractual Compliance has any ability to audit response times.

2. I find the reference to "GDPR legal bases" problematic. For example, under the current proposals, a registrar who is operating full outside of the EU mat redact information for legal persons and for natural persons not subject to the GDPR. What is the GDPR legal basis for requesting information on such registrations. According to GDPR there was no need for redaction to begin with, so a registrar can refuse to provide any results with full impunity.

Alan




On 1/31/2019 11:31 PM, Kurt Pritz wrote:

Hello Everyone: 
Thanks again for your perseverance. And - thank you in advance
for your spirit of cooperation and compromise in considering the
attached. We have spent the last few days reviewing the transcripts and
other records of our recent discussions and then amending the Final
Report Recommendations - taking into account the Initial Report
Recommendations, the small team work, the conclusions in Toronto and
these last several meetings. 
The Recommendations included here are:  
Recommendation 5 - Data elements to be transferred from
Registrars to Registries


Recommendation 10 - Email communication

Recommendation 12 - Reasonable Access


Recommendation 14 - Responsible Parties

[Not included are Rec. 13 (sent earlier) and Rec. 11 and the
Research Purpose (to be sent tomorrow.]


Each of these documents has a brief forward containing a
description of the pertinent discussion and an explanation for choosing
the wording in the Recommendations. They each then contain the
Recommendation as originally written and a redline of the proposed
recommendation based on the most recent discussions.  Please read
the entire documents (they are not long), and not just the recommendation
itself. 

I am certainly not asking for you to stand silently by if you
disagree with these Recommendations because they would negatively impact
GDPR compliance. I am asking that you study the balancing that went into
this and be ready to accept wording in cases where it does not match your
own choice. 
Please review with your groups and return to us by Monday so
that we can put any of these on the Tues/Wed/Thur agendas.



Sincerely,

Kurt
(Recommendation 12 attached)