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

[Ayden Férdeline]

There are some more edits now; the final language is in the attached PDF, and I think Stephanie has done a good job at noting the limitations of Article 6. I plan to submit the attached file on behalf of the NCSG EPDP team in 30 minutes time, unless I am directed otherwise. Thanks!

Ayden

‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
On Monday, 8 July 2019 22:53, farzaneh badii <farzaneh.badii at gmail.com> wrote:

> 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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