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

Tue Jul 9 03:06:26 EEST 2019

hi all,

based on last responses and after quick review of the latest version, I
think we can submit the comment.
@Stephanie or any EPDP member here can  do it?

Best,

Rafik

Le mar. 9 juil. 2019 à 07:51, Martin Pablo Silva Valent <
mpsilvavalent at gmail.com> a écrit :

> 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
>>>>>
>>>>>
>>>>>
>>>>
>>> _______________________________________________
>>> NCSG-PC mailing list
>>> NCSG-PC at lists.ncsg.is
>>> https://lists.ncsg.is/mailman/listinfo/ncsg-pc
>>>
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