Hello again. Apparently the following failed to be circulated as well. Please see below. From: Heineman, Ashley Sent: Thursday, May 30, 2019 9:59 AM To: gnso-epdp-team@icann.org Subject: RE: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Dear colleagues, In addition to the legal memo questions, the GAC Small Group proposes the following as a broader Phase 2 legal question for consideration. Can a centralized access/disclosure model (one in which a single entity is responsible for receiving disclosure requests, conducting the balancing test, checking accreditation, responding to requests, etc.) be designed in such a way as to limit the liability for the contracted parties to the greatest extent possible? IE - can it be opined that the centralized entity can be largely (if not entirely) responsible for the liability associated with disclosure (including the accreditation and authorization) and could the contracted parties’ liability be limited to activities strictly associated with other processing not related to disclosure, such as the collection and secure transfer of data? If so, what needs to be considered/articulated in policy to accommodate this? From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Georgios.TSELENTIS@ec.europa.eu<mailto:Georgios.TSELENTIS@ec.europa.eu> Sent: Thursday, May 30, 2019 7:12 AM To: vgreimann@key-systems.net<mailto:vgreimann@key-systems.net>; milton@gatech.edu<mailto:milton@gatech.edu> Cc: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Dear Volker, Milton, EPDP colleagues, I am reading with great interest the reactions to the clarification questions we sent, in particular regarding accuracy. The mere fact that the community has different understandings as to what exactly it means in the WHOIS policy reform under GDPR begs for asking those questions and not putting the issue (again) under the carpet. We might come with an outcome that current accuracy measures are sufficient for WHOIS GDPR compliance, or that we need more to do. Anyhow at this stage those are clarification questions not a policy per se so I would welcome first the legal counsel to provide some informed opinion before any community jumping to conclusions. Best regards, Georgios From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Volker Greimann Sent: Wednesday, May 29, 2019 6:54 PM To: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Hi Margie, the risk of the poor registrant losing his domain name due to inaccurate whois data is actually entirely of ICANNs making as contracted parties certainly do not need this data set for the purposes of maintaining the registration. We have account data for that. The only reason whois inaccuracies can cause a registrant to lose his domain is ICANN policies and contractual obligations regarding failures to update inaccurate data and registrars opting for deletion instead of deactivation (do such registrars still exist?). For all other purposes reasonable steps are already being taken, as I explained in my previous mail. Best, Volker Am 29.05.2019 um 18:38 schrieb Margie Milam: Hi Chris and all – To answer your question, the legal advice provided by Bird & Bird on accuracy addresses this issue and notes that there is a positive obligation on the controller to ensure the data is accurate depending on the circumstances and the consequences of processing inaccurate data. It also notes that a controller may have to get independent confirmation where the impact is particularly significant. In addition, the issue of data accuracy as part of a GDPR compliant system was also raised by the European Commission in its recent comments to the Board. In the case of domain names, the consequence of inaccurate data affects not just the registrant (who could lose its domain name), but those that may be trying to resolve technical issues, cyber-crime or consumer protection issues. We also have numerous studies conducted by ICANN over the last decade that show unacceptable levels of accuracy in the WHOIS system. This is why the question of accuracy was pushed to Phase 2 in our Phase 1 Final Report so that we could explore these issues further. See Footnote 6 where it says: The topic of accuracy as related to GDPR compliance is expected to be considered further as well as the WHOIS Accuracy Reporting System. All the best, Margie From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org><mailto:gnso-epdp-team-bounces@icann.org> on behalf of Chris Disspain <chris.disspain@board.icann.org><mailto:chris.disspain@board.icann.org> Date: Tuesday, May 28, 2019 at 9:48 AM To: "gnso-epdp-team@icann.org"<mailto:gnso-epdp-team@icann.org> <gnso-epdp-team@icann.org><mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Greetings All, I’m a little confused by this discussion. Apologies in advance if the below is wrong or naive or has been covered before. I don’t understand the connection between accuracy and GDPR. The regulations govern a registrars right to collect the data and what they can do with it. Assuming they have that right under GDPR, the registrants obligation to provide them with *accurate* data is not governed by GDPR but rather the contractual relationship between registrar and registrant and the registrar is entitled to require accurate information from the registrant pursuant to that. The registrar can also require the updating of changed information and/or proactively seek re-confirmation of accuracy. And ICANN, in its contract with a registrar, can require that registrar to require the registrant to provide accurate information. Other than governing the right to collect the information (and what can be done with it) does GDPR have some other role that I’m missing? Cheers, Chris On 28 May 2019, at 17:23, Volker Greimann <vgreimann@key-systems.net<mailto:vgreimann@key-systems.net>> wrote: Didn't we have (and settle) the same argument about six months ago? This principle is a protection of the data subject. When we create personal data from the data provided to us by the data subject or a third party, we must ensure we store it accurately and our processing does not falsify it. As such, the contractual provision that the data subject must provide to us accurate data (and keep uit updated when it changes) and the confirmation of the accuracy by the data subject is sufficient for our purposes and therefore reasonable in accordance with this principle. The principles protect the data subject, not third parties. Can we now please stop going over old settled issues? Volker Am 28.05.2019 um 18:06 schrieb Greg Aaron: Milton, no, the word “accuracy” does not appear only in GDPR Article 18. It appears most prominently in Article 5, which says: Art. 5 GDPR Principles relating to processing of personal data "1. Personal data shall be: ... (d) accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);… 2. The controller shall be responsible for, and be able to demonstrate compliance with, paragraph 1 (‘accountability’).” There has been discussion in legal and GDPR compliance communities that the above means all of these: a) Controllers have some responsibilities to take positive steps to ensure data collected from subjects is accurate. b) Organizations must allow data subjects to rectify inaccuracies. (Your point.) c) The data controller must carefully consider any challenges to the accuracy of information – no matter where that challenge comes from. d) Organizations must identify essential steps to erase or rectify inaccurate data without delay. And, e) Within some limits, the parties to a Date Sharing Agreement are free to agree on terms and conditions applicable to their sharing of data – for example specific obligations and warranties about the accuracy and completeness of data. How far the above extend, and how they apply to RDS data, is a Phase 2 subject for exploration. GDPR certainly discourages the submission or maintenance of data that is incorrect or misleading. And Article 5 seems to mean more than “trust implicitly whatever the data subject says, and correct the data only if the data subject itself requests.” The GDPR may contain some balancing mechanisms here, and proportionality is a general principle of EU law. So, given all that, and because there’s not a common understanding within our group, these issues are definitely good ones to ask Bird & Bird about. All best, --Greg From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org><mailto:gnso-epdp-team-bounces@icann.org> On Behalf Of Mueller, Milton L Sent: Saturday, May 25, 2019 9:18 AM To: Georgios.TSELENTIS@ec.europa.eu<mailto:Georgios.TSELENTIS@ec.europa.eu>; caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org> Cc: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Dear Georgios and colleagues: I think the questions related to accuracy below are not worth sending to the lawyers. They are based on a fundamental misconception, one which we have identified many times. Accuracy in GDPR and other data protection law is a right _of the data subject_, not a right of third parties to accurate data about the data subject. To prove this, beyond a shadow of the doubt, let me note that the word “accuracy” appears in GDPR in only two places, in Art 18. Article 18, Right to restriction of processing: ----------------------------------------------------------- “The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;” So data subjects can contest the accuracy of data about them, or require controllers to verify its accuracy. There is NO OTHER reference to accuracy in the entire GDPR. Georgios’s questions are based on the assumption that third parties have a right to accurate contact data about the data subject. That assumption was embedded in the old Whois and pre-GDPR Whois accuracy policies, all of which were predicated on indiscriminate publication of the contact data to any and all third parties. That regime is gone. And it’s recognized even by the most militant pro-surveillance interests that such indiscriminate disclosure is illegal. Likewise, Georgios asks about liability under Article 82 of GDPR. Again all we need to do is actually read Art 82 to find the answer: Article 82 says “Any person who has suffered material or non-material damage as a result of an infringement of this Regulation shall have the right to receive compensation from the controller or processor for the damage suffered.” So this is a right of PERSONS (data subjects) to compensation based on illegal acts of controllers and processors of THEIR data. It is not a right of third parties to accurate information about the data subject, and it certainly creates no liability for controllers or processors for the inaccuracy of the registrants’ data. Dr. Milton L Mueller Georgia Institute of Technology School of Public Policy From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Georgios.TSELENTIS@ec.europa.eu<mailto:Georgios.TSELENTIS@ec.europa.eu> Sent: Friday, May 24, 2019 7:02 PM To: caitlin.tubergen@icann.org<mailto:caitlin.tubergen@icann.org> Cc: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Dear Caitlin, colleagues, Please find below questions on the topics of the legal memos from the GAC: Accuracy . If current verification statistics provide that a large number of data is inaccurate isn't that a metric to deduce that the accuracy principle is not served in a reasonable manner as demanded by the GDPR? . According to the GDPR all personal data are processed based on the principle that they are necessary for the purpose for which they are collected. If those data are necessary, how can the purpose be served while the data are inaccurate? . Can you provide an analysis on the third-parties mentioned in para 19 on which "ICANN and the relevant parties may rely on to confirm the accuracy of personal data if it is reasonable to do so"? Do they become in such a scenario data processors? . How does the accuracy principle in connection to the parties' liability has to be understood in light of the accountability principle of the GDPR? What are the responsibilities of ICANN and the contracted parties (who are subject to the GDPR) under Chapter IV pf the GDPR? If the contracted parties (as data controllers) engage third entities as processors (e.g. to provide data back-up services), what are the responsibilities of these entities? What does this mean in terms of liabilities (in light of Art. 82 GDPR)? . While in the first place it is up to the registrants to provide accurate details about themselves and it is up to the registrants not to mistakenly identify themselves as natural or legal persons, the Memo on "Natural vs Legal persons" provides interesting ideas/suggestions for the contracted parties to proactively ensuring the reliability of information provided, including through measures to independently verify the data. Could similar mechanisms be identified also for ensuring the reliability of the contact details of the registrant? Can best practices be drawn from the ccTLD? Natural or non-natural persons . How is the (inaccurate or accurate) designation by the registrant about her status as non-natural person considered personal data information? If it's not is the analysis about whether the accuracy principle applies relevant? . How would the analysis provided take into account the possibility for registrants who are natural persons to "opt-in" for a full publication of their personal data? Indeed it might be the case that some of these registrants might wish to ensure their details are available on WHOIS. Technical contact Most of the issue for not allowing this seems to be around the inability to verify if the RNH has obtained consent from the technical contact. When the CP's verify the email address could consent also be confirmed for the term of the registration? General question: . How could anonymisatio/pseudonymisation techniques be of help in complying with the GDPR while also allowing for additional disclosure of certain data elements? E.g. use of anonymised/pseudonymised emails and names, in particular in the context of registrations by legal persons. Apologies again for the delay of our submission. Georgios Tselentis (GAC-EPDP) From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org<mailto:gnso-epdp-team-bounces@icann.org>> On Behalf Of Caitlin Tubergen Sent: Wednesday, May 22, 2019 5:22 PM To: gnso-epdp-team@icann.org<mailto:gnso-epdp-team@icann.org> Subject: [Gnso-epdp-team] For your review - Clarifying Legal Questions Table Dear EPDP Team, Following up on an action item from our last meeting, please find attached a table which organizes the clarifying legal questions received to date. We will discuss the table during our next meeting. Please note that the deadline for submitting additional clarifying questions is before 14:00 UTC on Thursday, 23 May. If additional questions come in before the deadline, we will update the table accordingly. Thank you. 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You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. _______________________________________________ Gnso-epdp-team mailing list Gnso-epdp-team@icann.org<mailto:Gnso-epdp-team@icann.org> https://mm.icann.org/mailman/listinfo/gnso-epdp-team<https://gcc01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fmm.icann.org%2Fmailman%2Flistinfo%2Fgnso-epdp-team&data=02%7C01%7CAHeineman%40ntia.gov%7C4726f807f3f843e8a9ec08d6e4efb555%7Cd6cff1bd67dd4ce8945dd07dc775672f%7C0%7C0%7C636948115549770167&sdata=GNxlcJN2l7E74z1j%2B%2F%2F1mnE9hNZK6m5nFoJHwPiEyzU%3D&reserved=0> _______________________________________________ By submitting your personal data, you consent to the processing of your personal data for purposes of subscribing to this mailing list accordance with the ICANN Privacy Policy (https://www.icann.org/privacy/policy<https://gcc01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.icann.org%2Fprivacy%2Fpolicy&data=02%7C01%7CAHeineman%40ntia.gov%7C4726f807f3f843e8a9ec08d6e4efb555%7Cd6cff1bd67dd4ce8945dd07dc775672f%7C0%7C0%7C636948115549770167&sdata=KZxCXtAVpeY%2FXGgn0fGKtdGsQvfA3qxJRVGx7dqfoH0%3D&reserved=0>) and the website Terms of Service (https://www.icann.org/privacy/tos<https://gcc01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.icann.org%2Fprivacy%2Ftos&data=02%7C01%7CAHeineman%40ntia.gov%7C4726f807f3f843e8a9ec08d6e4efb555%7Cd6cff1bd67dd4ce8945dd07dc775672f%7C0%7C0%7C636948115549780179&sdata=EVeyeYGyr7w8%2FlnriHpfaYY7Vtkmcz8PrQk9%2BloFgvE%3D&reserved=0>). You can visit the Mailman link above to change your membership status or configuration, including unsubscribing, setting digest-style delivery or disabling delivery altogether (e.g., for a vacation), and so on. -- Volker A. Greimann General Counsel and Policy Manager KEY-SYSTEMS GMBH T: +49 6894 9396901 M: +49 6894 9396851 F: +49 6894 9396851 W: www.key-systems.net<https://gcc01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.key-systems.net&data=02%7C01%7CAHeineman%40ntia.gov%7C4726f807f3f843e8a9ec08d6e4efb555%7Cd6cff1bd67dd4ce8945dd07dc775672f%7C0%7C0%7C636948115549780179&sdata=%2BktSJkQg5hrpCtd5O04s23sUQHYGvG4IyHITII1Zkds%3D&reserved=0> Key-Systems GmbH is a company registered at the local court of Saarbruecken, Germany with the registration no. HR B 18835 CEO: Alexander Siffrin Part of the CentralNic Group PLC (LON: CNIC) a company registered in England and Wales with company number 8576358.