ICANN follow up on Belgian DPA response to Strawberry letter
Janis and EPDP2 working group, I would like an update on the status of ICANN org interactions with the European Commission, the Belgian DPA and the EDPB and importantly how that involvement may impact our work. Following the Belgian DPA response to the "Strawberry" paper ICANN org submitted to the EDPB, we briefly discussed the response during plenary calls (36, 37). The notes from the 19 December meeting ask the questions: - Is ICANN expecting an additional communication on the Strawberry letter? - Would ICANN org like feedback from the EPDP Team before it meets with the Belgian DPA? I still have these questions. If they have been answered, I'm not aware of it. I checked the transcript from call #36 and note the following from Georgios: -------- GEORGIOS TSELENTIS: Okay, thank you. You are right, Janis. That was the first letter sent by the Belgian DPA. We thought it was publicly [released] from ICANN org. Then we had the response of ICANN org. This is, to my understanding, an invitation to provide more information also regarding the content of the model and how this is compliant with the policy that was developed to conduct GDPR according to the policy that we developed in the EPDP. So my understanding is that there's going to be a round of, again, a formal technical meeting between ICANN org and the Belgian DPA before having a formal reply to the policy guidance, which was sent out in the original letter. So our reading was that - I'm talking here with the hat on of the [inaudible] - there is a need for more information. There's many issues which are developed under also the EPDP in order for the Belgian DPA to make [inaudible] there is normally a DPA which is taking the lead and introduces the [subject to the Board] before having a formal reply. But we are still at the stage where the Belgian DPA, which is a penholder for this process, is seeking more information. In my understanding, in the beginning of January, there are seeking to have a technical meeting to have more information. This is as much information I have from my side. Thanks. ------- This seems to indicate that there will be future interactions involving ICANN Org, the European Commission and the Belgian DPA. Given our timelines and the current state of our work, it is critical that we understand the status of these discussions and how they may impact our work. I'm not sure the best way to get clarity on this, perhaps our ICANN org liaisons can provide an update or maybe a request from Janis to ICANN org asking for details. As it stands now though, I don't know if any further communication is going on, and if it is, what is being discussed. Thank you, Marc ICANN announcement of "Strawberry" paper to EDPB: https://www.icann.org/news/blog/icann-org-seeks-european-data-protection-boa... Belgian DPA response: https://www.icann.org/en/system/files/correspondence/stevens-to-marby-04dec1... ICANN notice of Belgian DAP response: https://www.icann.org/news/announcement-2019-12-17-en Meeting 36 (19 Dec 2019) - notes: https://community.icann.org/display/EOTSFGRD/2019-12-19+EPDP-+Phase+2+call+%... Meeting 36 Transcript: https://gnso.icann.org/sites/default/files/policy/2019/transcript/transcript...
Agreed. Thanks for raising this, Marc. Brian J. King Director of Internet Policy and Industry Affairs T +1 443 761 3726 markmonitor.com<http://www.markmonitor.com> MarkMonitor Protecting companies and consumers in a digital world From: Gnso-epdp-team <gnso-epdp-team-bounces@icann.org> On Behalf Of Anderson, Marc via Gnso-epdp-team Sent: Friday, January 17, 2020 11:41 PM To: gnso-epdp-team@icann.org Subject: [Gnso-epdp-team] ICANN follow up on Belgian DPA response to Strawberry letter Janis and EPDP2 working group, I would like an update on the status of ICANN org interactions with the European Commission, the Belgian DPA and the EDPB and importantly how that involvement may impact our work. Following the Belgian DPA response to the "Strawberry" paper ICANN org submitted to the EDPB, we briefly discussed the response during plenary calls (36, 37). The notes from the 19 December meeting ask the questions: - Is ICANN expecting an additional communication on the Strawberry letter? - Would ICANN org like feedback from the EPDP Team before it meets with the Belgian DPA? I still have these questions. If they have been answered, I'm not aware of it. I checked the transcript from call #36 and note the following from Georgios: -------- GEORGIOS TSELENTIS: Okay, thank you. You are right, Janis. That was the first letter sent by the Belgian DPA. We thought it was publicly [released] from ICANN org. Then we had the response of ICANN org. This is, to my understanding, an invitation to provide more information also regarding the content of the model and how this is compliant with the policy that was developed to conduct GDPR according to the policy that we developed in the EPDP. So my understanding is that there's going to be a round of, again, a formal technical meeting between ICANN org and the Belgian DPA before having a formal reply to the policy guidance, which was sent out in the original letter. So our reading was that - I'm talking here with the hat on of the [inaudible] - there is a need for more information. There's many issues which are developed under also the EPDP in order for the Belgian DPA to make [inaudible] there is normally a DPA which is taking the lead and introduces the [subject to the Board] before having a formal reply. But we are still at the stage where the Belgian DPA, which is a penholder for this process, is seeking more information. In my understanding, in the beginning of January, there are seeking to have a technical meeting to have more information. This is as much information I have from my side. Thanks. ------- This seems to indicate that there will be future interactions involving ICANN Org, the European Commission and the Belgian DPA. Given our timelines and the current state of our work, it is critical that we understand the status of these discussions and how they may impact our work. I'm not sure the best way to get clarity on this, perhaps our ICANN org liaisons can provide an update or maybe a request from Janis to ICANN org asking for details. As it stands now though, I don't know if any further communication is going on, and if it is, what is being discussed. Thank you, Marc ICANN announcement of "Strawberry" paper to EDPB: https://www.icann.org/news/blog/icann-org-seeks-european-data-protection-board-input<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_news_blog_icann-2Dorg-2Dseeks-2Deuropean-2Ddata-2Dprotection-2Dboard-2Dinput&d=DwMFAg&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6OAPSNnJsG8xl-nhwtOYRnBmIdI6v8_5jC7BC2ommWI&s=5rT_P5cTbpkV4vNQuCkmFWmpqmtH691HPT4M-U8sH9I&e=> Belgian DPA response: https://www.icann.org/en/system/files/correspondence/stevens-to-marby-04dec19-en.pdf<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_en_system_files_correspondence_stevens-2Dto-2Dmarby-2D04dec19-2Den.pdf&d=DwMFAg&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6OAPSNnJsG8xl-nhwtOYRnBmIdI6v8_5jC7BC2ommWI&s=oXIlJEuCvc7O_wVI-xybjDiYMNkmRVTaMgAcpeVX_H4&e=> ICANN notice of Belgian DAP response: https://www.icann.org/news/announcement-2019-12-17-en<https://urldefense.proofpoint.com/v2/url?u=https-3A__www.icann.org_news_announcement-2D2019-2D12-2D17-2Den&d=DwMFAg&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6OAPSNnJsG8xl-nhwtOYRnBmIdI6v8_5jC7BC2ommWI&s=yYe95tlL83RY1cGjrAAyknYcVhCk6kgc6xQkf_95SR8&e=> Meeting 36 (19 Dec 2019) - notes: https://community.icann.org/display/EOTSFGRD/2019-12-19+EPDP-+Phase+2+call+%2336<https://urldefense.proofpoint.com/v2/url?u=https-3A__community.icann.org_display_EOTSFGRD_2019-2D12-2D19-2BEPDP-2D-2BPhase-2B2-2Bcall-2B-252336&d=DwMFAg&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6OAPSNnJsG8xl-nhwtOYRnBmIdI6v8_5jC7BC2ommWI&s=HZKakPvyHHf_ecx55iVO1ZzmxlrYID1QndQmDapBHpg&e=> Meeting 36 Transcript: https://gnso.icann.org/sites/default/files/policy/2019/transcript/transcript-gnso-epdp-p2-19dec19-en.pdf<https://urldefense.proofpoint.com/v2/url?u=https-3A__gnso.icann.org_sites_default_files_policy_2019_transcript_transcript-2Dgnso-2Depdp-2Dp2-2D19dec19-2Den.pdf&d=DwMFAg&c=OGmtg_3SI10Cogwk-ShFiw&r=qQNCXqU_XE2XIdXbawYmk-YDflYH6pd8ffXlzxU37OA&m=6OAPSNnJsG8xl-nhwtOYRnBmIdI6v8_5jC7BC2ommWI&s=5g36MYUqhWtYsj-MJGRSBhqhHbe8fGg8eqk5OKf-l-s&e=>
participants (2)
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Anderson, Marc -
King, Brian