I have raised this point several times and I see it being avoided. The redacted data elements are one of the most important aspects of the temp spec. It is imperative that this group identify specifically which redactions we agree with and which ones certain stakeholders don't agree with. This should be very simple to do. I would propose that we add to the Triage report a simple list of each redacted data element, and then list who agrees and disagrees with its redaction. Those opposing a redaction must explain why they think publishing that data is consistent with GDPR and other privacy laws that may apply. My understanding is that the NCSG, RySG, RrSG, ALAC and ISPC all are ok with the current set of redactions under the temp spec. It is therefore incumbent upon the BC, IPC, and GAC to specify which data elements they think should be published and which they are ok with redacting. Again, this seems like a very simple thing to do and as a form of "triage" would be most helpful for the group's progress Dr. Milton L. Mueller Professor, School of Public Policy Georgia Institute of Technology
Milton, Let me qualify the ISPCP input: Not redacting the „Organization“ field is problematic. Best, Thomas
Am 23.08.2018 um 15:00 schrieb Mueller, Milton L <milton@gatech.edu>:
I have raised this point several times and I see it being avoided. The redacted data elements are one of the most important aspects of the temp spec. It is imperative that this group identify specifically which redactions we agree with and which ones certain stakeholders don’t agree with. This should be very simple to do. I would propose that we add to the Triage report a simple list of each redacted data element, and then list who agrees and disagrees with its redaction. Those opposing a redaction must explain why they think publishing that data is consistent with GDPR and other privacy laws that may apply.
My understanding is that the NCSG, RySG, RrSG, ALAC and ISPC all are ok with the current set of redactions under the temp spec. It is therefore incumbent upon the BC, IPC, and GAC to specify which data elements they think should be published and which they are ok with redacting. Again, this seems like a very simple thing to do and as a form of “triage” would be most helpful for the group’s progress
Dr. Milton L. Mueller Professor, School of Public Policy Georgia Institute of Technology
_______________________________________________ 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://mm.icann.org/mailman/listinfo/gnso-epdp-team>
Thanks, Thomas. So you want possibly more redaction. I will add that to the list. From: Thomas Rickert [mailto:epdp@gdpr.ninja] Sent: Thursday, August 23, 2018 9:05 AM To: Mueller, Milton L <milton@gatech.edu> Cc: Thomas Rickert <epdp@gdpr.ninja>; gnso-epdp-team@icann.org Subject: Re: [Gnso-epdp-team] redacted data Milton, Let me qualify the ISPCP input: Not redacting the „Organization“ field is problematic. Best, Thomas Am 23.08.2018 um 15:00 schrieb Mueller, Milton L <milton@gatech.edu<mailto:milton@gatech.edu>>: I have raised this point several times and I see it being avoided. The redacted data elements are one of the most important aspects of the temp spec. It is imperative that this group identify specifically which redactions we agree with and which ones certain stakeholders don’t agree with. This should be very simple to do. I would propose that we add to the Triage report a simple list of each redacted data element, and then list who agrees and disagrees with its redaction. Those opposing a redaction must explain why they think publishing that data is consistent with GDPR and other privacy laws that may apply. My understanding is that the NCSG, RySG, RrSG, ALAC and ISPC all are ok with the current set of redactions under the temp spec. It is therefore incumbent upon the BC, IPC, and GAC to specify which data elements they think should be published and which they are ok with redacting. Again, this seems like a very simple thing to do and as a form of “triage” would be most helpful for the group’s progress Dr. Milton L. Mueller Professor, School of Public Policy Georgia Institute of Technology _______________________________________________ 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
We know that the organization field has the same information as the registrant field. Therefore, a logical consequence should be a redaction requirement for the org field, too. However, as I mentioned in the chat during the last call: The problem could go away if the EDPB gave its blessing to using the registrant’s self-identification as a compliant solution for distinguishing between natural and legal persons. Thomas
Am 23.08.2018 um 15:19 schrieb Mueller, Milton L <milton@gatech.edu>:
Thanks, Thomas. So you want possibly more redaction. I will add that to the list.
<> From: Thomas Rickert [mailto:epdp@gdpr.ninja <mailto:epdp@gdpr.ninja>] Sent: Thursday, August 23, 2018 9:05 AM To: Mueller, Milton L <milton@gatech.edu <mailto:milton@gatech.edu>> Cc: Thomas Rickert <epdp@gdpr.ninja <mailto:epdp@gdpr.ninja>>; gnso-epdp-team@icann.org <mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] redacted data
Milton, Let me qualify the ISPCP input: Not redacting the „Organization“ field is problematic.
Best, Thomas
Am 23.08.2018 um 15:00 schrieb Mueller, Milton L <milton@gatech.edu <mailto:milton@gatech.edu>>:
I have raised this point several times and I see it being avoided. The redacted data elements are one of the most important aspects of the temp spec. It is imperative that this group identify specifically which redactions we agree with and which ones certain stakeholders don’t agree with. This should be very simple to do. I would propose that we add to the Triage report a simple list of each redacted data element, and then list who agrees and disagrees with its redaction. Those opposing a redaction must explain why they think publishing that data is consistent with GDPR and other privacy laws that may apply.
My understanding is that the NCSG, RySG, RrSG, ALAC and ISPC all are ok with the current set of redactions under the temp spec. It is therefore incumbent upon the BC, IPC, and GAC to specify which data elements they think should be published and which they are ok with redacting. Again, this seems like a very simple thing to do and as a form of “triage” would be most helpful for the group’s progress
Dr. Milton L. Mueller Professor, School of Public Policy Georgia Institute of Technology
_______________________________________________ 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://mm.icann.org/mailman/listinfo/gnso-epdp-team>
Sorry, the first sentence was not finished: ...has the same information as the registrant field in many cases. …it should read. I guess the portion is around 60%. Thomas
Am 23.08.2018 um 15:23 schrieb Thomas Rickert <epdp@gdpr.ninja>:
We know that the organization field has the same information as the registrant field. Therefore, a logical consequence should be a redaction requirement for the org field, too.
However, as I mentioned in the chat during the last call: The problem could go away if the EDPB gave its blessing to using the registrant’s self-identification as a compliant solution for distinguishing between natural and legal persons.
Thomas
Am 23.08.2018 um 15:19 schrieb Mueller, Milton L <milton@gatech.edu <mailto:milton@gatech.edu>>:
Thanks, Thomas. So you want possibly more redaction. I will add that to the list.
<> From: Thomas Rickert [mailto:epdp@gdpr.ninja <mailto:epdp@gdpr.ninja>] Sent: Thursday, August 23, 2018 9:05 AM To: Mueller, Milton L <milton@gatech.edu <mailto:milton@gatech.edu>> Cc: Thomas Rickert <epdp@gdpr.ninja <mailto:epdp@gdpr.ninja>>; gnso-epdp-team@icann.org <mailto:gnso-epdp-team@icann.org> Subject: Re: [Gnso-epdp-team] redacted data
Milton, Let me qualify the ISPCP input: Not redacting the „Organization“ field is problematic.
Best, Thomas
Am 23.08.2018 um 15:00 schrieb Mueller, Milton L <milton@gatech.edu <mailto:milton@gatech.edu>>:
I have raised this point several times and I see it being avoided. The redacted data elements are one of the most important aspects of the temp spec. It is imperative that this group identify specifically which redactions we agree with and which ones certain stakeholders don’t agree with. This should be very simple to do. I would propose that we add to the Triage report a simple list of each redacted data element, and then list who agrees and disagrees with its redaction. Those opposing a redaction must explain why they think publishing that data is consistent with GDPR and other privacy laws that may apply.
My understanding is that the NCSG, RySG, RrSG, ALAC and ISPC all are ok with the current set of redactions under the temp spec. It is therefore incumbent upon the BC, IPC, and GAC to specify which data elements they think should be published and which they are ok with redacting. Again, this seems like a very simple thing to do and as a form of “triage” would be most helpful for the group’s progress
Dr. Milton L. Mueller Professor, School of Public Policy Georgia Institute of Technology
_______________________________________________ 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://mm.icann.org/mailman/listinfo/gnso-epdp-team>
participants (2)
-
Mueller, Milton L -
Thomas Rickert