PII and this definition relates to individuals.  If the proxy registration is for a battered women's shelter, the address and phone number do not relate to an individual or at least do not lead to the identification of an individual.  I think using PII (which is different from PI, and not what is usually found in data protection law) leads us into waters that we dont need to enter.  We must remember that proxy services are used for groups, even companies.
Stephanie P

On 2015-04-14 12:03, Kiran Malancharuvil wrote:

Hi Kathy,

 

How does Terri’s language exclude those groups?

 

Thanks,


Kiran

 

From: gnso-ppsai-pdp-wg-bounces@icann.org [mailto:gnso-ppsai-pdp-wg-bounces@icann.org] On Behalf Of Kathy Kleiman
Sent: Tuesday, April 14, 2015 9:01 AM
To: gnso-ppsai-pdp-wg@icann.org
Subject: Re: [Gnso-ppsai-pdp-wg] Section III-C-(5)

 

Terry,
I much prefer the original language since we are also working with the privacy and speech protections also of political groups, battered women's shelters, minority religious groups, Mom- and home-based small businesses, etc. -- the wide array of legitimate groups, organizations and businesses that use proxy/privacy providers.
Best,
Kathy

:

Perhaps I am over-simplifying, but since agreement has not been reached on the current language, and III-C-(3) actually gives the provider quite a bit of lee-way to decide against disclosure, I propose the following: 

 

the Provider has found, specific information, facts and/or circumstances that reveal the Requestor's trademark or copyright complaint is a pretextual means of obtaining the Customer's contact details solely for the purpose of contravening the Customer's personally identifiable information.

1.       Personally identifiable information (PII) is any data that could potentially identify a specific individual. Any information that can be used to distinguish one person from another and can be used for de-anonymizing anonymous data can be considered PII.

 

--

Terri Stumme

Intellligence Analyst




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