Draft letter to the Article 29 Working Party

[Stephanie Perrin]

You will find attached a draft letter to the EU Article 29 Working 
Party, which we propose to send on Friday March 2nd.  Please let me or 
the policy committee know if you have comments.

As you are probably aware, ICANN is in the process of determining an 
interim measure to comply better with the General Data Protection 
Regulation (GDPR) which comes into effect on May 25, and carries the 
potential for fines of 4% of revenues.  ICANN Chief Executive Officer 
Goran Marby has encouraged ICANN stakeholders to contact the Article 29 
Working Party seeking guidance and engagement.   The Article 29 Working 
Party is the group of data commissioners tasked by Article 29 of the 
current Data Protection 95/46 to determine adequacy of the data 
protection law in third countries that receive the data of EU citizens.  
The Article 29 WP becomes the Data Protection Board under the new 
regulation after May 25, and will have authority to coordinate 
enforcement action.

Given that some other stakeholders have written to them, we decided we 
had better make our views known.  For the latest updates on ICANN 
compliance on the GDPR, please check the data protection page at 
https://www.icann.org/dataprotectionprivacy.  There is quite a bit 
happening, but the final model for the interim measures is still a 
moving target.

Stephanie Perrin

GNSO Councillor, NCSG

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