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

Tue Jul 9 01:42:05 EEST 2019

All,
If you need PC support for its submissions, I reiterate mine — now after
Steph made edits it looks like ready to me.
Cheers,
Tanya

On Tue 9. Jul 2019 at 00:17, Ayden Férdeline <icann at ferdeline.com> wrote:

> Ok, I will leave you/someone else to submit it then, as I will not be
> online at that time.
>
> Thanks, Ayden
>
>
> ‐‐‐‐‐‐‐ Original Message ‐‐‐‐‐‐‐
> On Monday, 8 July 2019 23:05, Rafik Dammak <rafik.dammak at gmail.com> wrote:
>
> 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
>>>
>>>
>>>
>>
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