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ICANN org has been open and transparent with our engagements with the EDPB and DPAs. All of the formal written communications from EDPB and DPAs are published on ICANN correspondence. In addition, we’ve had informal verbal conversations with the EDPB and DPAs to educate, inform, and ask for guidance. Summaries of those informal conversations are published in blogs. To assist the EPDP Team in its work, ICANN org will provide the EPDP Team with a compiled list of correspondence received and blogs published thus far, including the topic of each correspondence/blog. See DPA Advice Summary-DRAFT.xlsx.

3. Is there any further information that can be provided in relation to the discussions that have been held with the EDPB and/or DPAs in addition to the blog posts and correspondence that have been shared, such as briefing notes and summaries of meetings?

Aside from the blog posts and correspondence that have already been shared, and consistent with ICANN Publication Practices, ICANN org has not identified any additional notes or summaries of meetings that are suitable for publication.

ICANN org has previously stated that having clear guidance may increase legal certainty for ICANN and the contracted parties as well as assist the community in the Expedited Policy Development Process (EPDP) to consider the Temporary Specification for gTLD Registration Data (Temp Spec). Our commitment to transparency in publishing summaries of our interactions with the EDPB supports this stated purpose.

In this regard, we’ve posted summaries of our conversations with the EDPB and DPAs on ICANN’s Data Protection/Privacy Issues page. The purpose of these conversations has been to educate, inform, and request guidance. In these discussions, we have also relayed to the EDPB the concerns and questions that we have solicited from the community.

Additionally, in the Work and Tools section of the EDPB website, the EDPB states that: “We issue general guidance to promote a common understanding of European data protection laws, both across the European Union and around the world. We clarify data protection provisions, advise the European Commission and provide the general public and stakeholders with our interpretation of their rights and obligations. We can issue guidelines, recommendations and best practices about the GDPR and the Law Enforcement Directive, as well as other documents.” Accordingly, guidance from the EDPB to ICANN is publicly posted on their website and ICANN’s website so that the guidance is available for all interested parties and can help inform the work of the community.

ICANN org's GDPR Compliance

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