[NCSG-PC] Fwd: [NCSG-Discuss] [feedback requested] EPDP Phase 2 Input Document

[farzaneh badii]

Thanks. I can see the edits. My concern considering we invoke  Article 6
for providing legal bases for third party disclosure remains but I guess we
can discuss those issues at EPDP.

I suggest that we also carry out a legitimate interest assessment.. all the
use cases that invoke 6(1)(f) should actually do a legitimate interest
assessment test. It is not too difficult. We can invoke their favorite data
protection authority method:
https://ico.org.uk/for-organisations/guide-to-data-protection/guide-to-the-general-data-protection-regulation-gdpr/legitimate-interests/how-do-we-apply-legitimate-interests-in-practice/






Farzaneh


On Mon, Jul 8, 2019 at 5:37 PM Ayden Férdeline <icann at ferdeline.com> wrote:

> Thanks Farzi, Stephanie has just added a huge of (very good) edits to the
> document, so I think it is in better shape now
>
>
> https://docs.google.com/document/d/1rK5gp2hjABl29lLMzdlqSR0jWIOSQa-Oc4R_nzrUmqo/edit?usp=sharing
>
> Ayden
>
>
> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
> On Monday, 8 July 2019 22:35, farzaneh badii <farzaneh.badii at gmail.com>
> wrote:
>
> Hi Ayden
>
> I had mentioned the problem of just citing Article 6 in my other comment
> on Google doc. But as I said I think it's ok to submit if Stephanie doesn't
> see there is an issue.
>
>
> On Sun, Jul 7, 2019 at 6:52 PM Ayden Férdeline <icann at ferdeline.com>
> wrote:
>
>> I did not resolve the comments in the Google Doc by pressing the
>> 'resolve' button, but I did respond to the comment offering a suggested
>> path forward, i.e. refer broadly to Article 6 of the GDPR. Please let me
>> know if this alternative language would work? But I agree it would be great
>> to get all members of the EPDP team to look over this document to make sure
>> its sound, so I hope others can review it as a matter of priority.
>>
>> Best wishes, Ayden
>>
>>
>> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
>> On Sunday, 7 July 2019 23:49, farzaneh badii <farzaneh.badii at gmail.com>
>> wrote:
>>
>> (Observer) I have commented on this draft. I don't see my comments
>> responded to and resolved. Basically I think if Stephanie with her
>> expertise in data protection doesn’t get the time to look at it to see if
>> the answers that have invoked GDPR are correct, then we run the risk of
>> having answered the questions invoking the wrong articles and providing the
>> wrong rational. we can submit without answering those questions that invoke
>> GDPR specific articles.  I think I have flagged them in the document but
>> will have a look again.
>>
>> On Sat, Jul 6, 2019 at 12:11 PM Ayden Férdeline <icann at ferdeline.com>
>> wrote:
>>
>>> Hi,
>>>
>>> I have not endorsed the contents of this document because I was involved
>>> in drafting it.
>>>
>>> But I hope other members of the Policy Committee can review it as a
>>> matter of priority and advise if it can be submitted or not. The due date
>>> is Monday, 8 July. Thanks.
>>>
>>> Best wishes, Ayden
>>>
>>>
>>> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
>>> On Wednesday, 3 July 2019 23:45, Rafik Dammak <rafik.dammak at gmail.com>
>>> wrote:
>>>
>>> Hi all,
>>>
>>> this need a swift action from PC: review and endorsment by deadline
>>> (which was already extended)
>>>
>>> Best,
>>>
>>> Rafik
>>> ---------- Forwarded message ---------
>>> De : *Ayden Férdeline* <icann at ferdeline.com>
>>> Date: jeu. 4 juil. 2019 à 07:43
>>> Subject: [NCSG-Discuss] [feedback requested] EPDP Phase 2 Input Document
>>> To: <NCSG-DISCUSS at listserv.syr.edu>
>>>
>>>
>>> Dear all,
>>>
>>> As you might be aware, the EPDP (the working group looking at how Whois
>>> can be reformed to better safeguard privacy) has now commenced phase 2 of
>>> its work.
>>>
>>> The NCSG has been invited to offer its input to help inform the EPDP
>>> Team’s deliberations for phase 2 of its work, which will focus on 1) the
>>> system for accessing personal information, 2) the Annex to the Temporary
>>> Specification, and 3) issues deferred from phase 1.
>>>
>>> The NCSG's representatives to the EPDP have prepared a first draft to
>>> this input document, and we welcome your input here. Please take a look at
>>> the document here, and please let us know if you have any concerns,
>>> questions, or suggested edits:
>>> https://docs.google.com/document/d/1rK5gp2hjABl29lLMzdlqSR0jWIOSQa-Oc4R_nzrUmqo/edit?usp=sharing
>>>
>>> Our deadline for submitting this to the EPDP team is Monday, 8 July, so
>>> your prompt review would be greatly appreciated. Thank you for your
>>> understanding.
>>>
>>> Kind regards,
>>>
>>> Ayden Férdeline
>>> on behalf of the NCSG's representatives to the EPDP
>>>
>>>
>>> _______________________________________________
>>> NCSG-PC mailing list
>>> NCSG-PC at lists.ncsg.is
>>> https://lists.ncsg.is/mailman/listinfo/ncsg-pc
>>>
>> --
>> Farzaneh
>>
>>
>> --
> Farzaneh
>
>
>
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