Hi Chuck and All, Would it be possible to use a Google Doc? I think I used the most recent version of the DT5 document. I have to say that this document is very difficult for me to understand. Perhaps because the terms are ambiguous. "Contracted party" in ICANN generally means a registry and registrar. Is that how you are using it here? Further, throughout the world, contractual compliance documents (often third party documents to the customer and involving how a customer's data is processed by vendors, for example) are being modified to ensure that the fundamental protections and rights provided by data protection laws to the customers (registrants, in our case) are protected fully and consistent with the purpose of that collection and processing. Here, we seem to be making the contractual compliance obligations of third parties to the customer/registrant subservient to other agreements. I think we may have it backwards, but I am, of course new to the group. (I have however, studied and written about the EU-US Privacy Shield -- happy to share the links). Best regards, Kathy (with edited version of what I think is the most recent version of the document attached -- with Track Changes) On 3/2/2018 3:13 PM, Chuck wrote:
Thanks for the edits Steve.
I saved the redline version from Steve as version 2 of our deliverable. Does anyone have any more suggested edits? If so, please let us know by mid-day on Monday. Otherwise, I will assume that this is our final version for ICANN Contractual Compliance.
Who from this DT is going to be in Puerto Rico? It would be great if one of you could present our deliverable to the WG on Saturday morning. It could also be presented remotely.
Chuck
*From:* Metalitz, Steven [mailto:met@msk.com] *Sent:* Friday, March 2, 2018 9:04 AM *To:* 'Beth Bacon' <bbacon@pir.org>; 'Chuck' <consult@cgomes.com>; 'GNSO-RDS-pdp-5@icann.org' <GNSO-RDS-pdp-5@icann.org> *Subject:* RE: [Gnso-rds-pdp-5] FW: DT5 Answers to Questions - First Draft for DT Review
And here are a few edits re the ICANN contractual compliance piece, mainly to indicate that (1) compliance issues other than RDS compliance might apply and (2) ICANN compliance may need to contact registrants as part of a compliance investigation. Perhaps we should run this document by ICANN compliance to get their perspective….
Steve
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*From:*Metalitz, Steven *Sent:* Friday, March 02, 2018 11:46 AM *To:* 'Beth Bacon'; Chuck; GNSO-RDS-pdp-5@icann.org <mailto:GNSO-RDS-pdp-5@icann.org> *Subject:* RE: [Gnso-rds-pdp-5] FW: DT5 Answers to Questions - First Draft for DT Review
Thanks for getting the ball rolling Beth. See my edits/comments in attached.
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*Steven J. Metalitz *|***Partner, through his professional corporation*
T: 202.355.7902 | met@msk.com <mailto:met@msk.com>**
*Mitchell Silberberg & Knupp**LLP*|*www.msk.com <http://www.msk.com/>*
1818 N Street NW, 8th Floor, Washington, DC 20036
*_THE INFORMATION CONTAINED IN THIS E-MAIL MESSAGE IS INTENDED ONLY FOR THE PERSONAL AND CONFIDENTIAL USE OF THE DESIGNATED RECIPIENTS._**THIS MESSAGE MAY BE AN ATTORNEY-CLIENT COMMUNICATION, AND AS SUCH IS PRIVILEGED AND CONFIDENTIAL. IF THE READER OF THIS MESSAGE IS NOT AN INTENDED RECIPIENT, YOU ARE HEREBY NOTIFIED THAT ANY REVIEW, USE, DISSEMINATION, FORWARDING OR COPYING OF THIS MESSAGE IS STRICTLY PROHIBITED. PLEASE NOTIFY US IMMEDIATELY BY REPLY E-MAIL OR TELEPHONE, AND DELETE THE ORIGINAL MESSAGE AND ALL ATTACHMENTS FROM YOUR SYSTEM. THANK YOU.*
*From:*Gnso-rds-pdp-5 [mailto:gnso-rds-pdp-5-bounces@icann.org] *On Behalf Of *Beth Bacon *Sent:* Friday, March 02, 2018 11:22 AM *To:* Chuck; GNSO-RDS-pdp-5@icann.org <mailto:GNSO-RDS-pdp-5@icann.org> *Subject:* Re: [Gnso-rds-pdp-5] FW: DT5 Answers to Questions - First Draft for DT Review
Hello Team,
Please see my edits and comments in the attached. Please feel free to argue with me about my comments and questions. I’ve missed a few of the calls this month so my questions may be based on incorrect assumptions. I don’t have any edits to the compliance document.
Looking forward to seeing you in PR.
Best, Beth
*From:* Gnso-rds-pdp-5 [mailto:gnso-rds-pdp-5-bounces@icann.org] *On Behalf Of *Chuck *Sent:* Friday, March 02, 2018 11:00 AM *To:* GNSO-RDS-pdp-5@icann.org <mailto:GNSO-RDS-pdp-5@icann.org> *Subject:* [Gnso-rds-pdp-5] FW: DT5 Answers to Questions - First Draft for DT Review *Importance:* High
I have only heard from one team member so far and she plans to respond today. I sure hope the rest of you can respond today as well. I understand how much is going on including ICANN’s posting of the latest info on the GDPR memo, but please try to spend 30 minutes or so today and provide your initial input on these two documents so that we can have an email discussion about them over the weekend and on Monday.
Chuck
*From:* Gnso-rds-pdp-5 [mailto:gnso-rds-pdp-5-bounces@icann.org] *On Behalf Of *Chuck *Sent:* Thursday, March 1, 2018 9:01 AM *To:* GNSO-RDS-pdp-5@icann.org <mailto:GNSO-RDS-pdp-5@icann.org> *Subject:* [Gnso-rds-pdp-5] DT5 Answers to Questions - First Draft for DT Review *Importance:* High
It would be very helpful if each of you could review and provide any first thoughts you have on the following two drafts TODAY. Note that the first one is less than two pages and the second is only about half a page.
Chuck
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