Data Protection and Privacy Update: Seeking Community Feedback on Proposed Compliance Models

[Jeremy Malcolm]

I agree that 2B is an option we could live with, but I wonder whether,
since 3 is out there, wouldn't it be tactically better to support that? 
Even if it doesn't stand much chance, it's better aligned with our
principles. No need to jump straight to the compromise solution for
pragmatic reasons. That just invites compromising further. We could
accept 2B as a fallback.

Even with 2B, there could be some concerns around the "formal
accreditation/certification program" for gaining access to thick data.
The devil is definitely going to be in those details.

On 14/1/18 6:36 am, Ayden Férdeline wrote:
> I could live with the second model.
>
> The key differentiation between Model 2A and 2B is its applicability:
> 2A applies only "where the registrant, registry, registrar or a
> processor are located in the European Economic Area"; 2B "applies to
> all registrations on a global basis without regard to location of
> registry, registrar registrant, and processing activities"
>
> On this basis I think Model 2B is the best path forward. To have
> fragmented approaches for different regions would be a mistake, in my
> opinion.
>
> Given the short turnaround time here (we need to agree on a position
> and submit a comment by 29 January) and other obstacles between now
> and then (Intersessional, GNSO Council Strategic Planning Session),
> may I suggest that we schedule a call next week to discuss our response?
>
> Best wishes, Ayden
>
>
>> -------- Original Message --------
>> Subject: Data Protection and Privacy Update: Seeking Community
>> Feedback on Proposed Compliance Models
>> Local Time: 13 January 2018 7:40 PM
>> UTC Time: 13 January 2018 18:40
>> From: farzaneh.badii at GMAIL.COM
>> To: NCSG-DISCUSS at LISTSERV.SYR.EDU
>>
>> Please see the CEO blog on Data protection and privacy:
>>
>> https://www.icann.org/news/blog/data-protection-and-privacy-update-seeking-community-feedback-on-proposed-compliance-models
>>
>> We should understand these models, discuss them and provide feedback. 
>>
>> Best
>> Farzaneh
>

-- 
Jeremy Malcolm
Senior Global Policy Analyst
Electronic Frontier Foundation
https://eff.org
jmalcolm at eff.org

Tel: 415.436.9333 ext 161

:: Defending Your Rights in the Digital World ::

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