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

Tue Jul 9 01:51:03 EEST 2019

I fully support, endorse and thank all involved in such an decisive
document for NCSG.

Saludos,
Martin

On Mon, Jul 8, 2019, 7:42 PM Tatiana Tropina <tatiana.tropina at gmail.com>
wrote:

> 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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>> NCSG-PC at lists.ncsg.is
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>>
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