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

Tue Jul 9 04:37:38 EEST 2019

This comment was submitted, Stephanie cc'd.

Best
Farzaneh

On Mon, Jul 8, 2019 at 8:06 PM Rafik Dammak <rafik.dammak at gmail.com> wrote:

> 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
>>>>>>
>>>>>>
>>>>>>
>>>>>
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>>>>
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