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

[Rafik Dammak]

Hi,

Don't submit yet. The deadline is not 23:59 UTC.

Rafik

On Tue, Jul 9, 2019, 06:58 Ayden Férdeline <icann at ferdeline.com> wrote:

> 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
>>
>>
>>
>
-------------- next part --------------
An HTML attachment was scrubbed...
URL: <http://lists.ncsg.is/pipermail/ncsg-pc/attachments/20190709/db5b504e/attachment.htm>