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The procedure was also previously attempted by .FRL in late 2016 but the request did not meet the requirements to utilize the procedure. At the time, requirement to trigger the procedure was that the contracted party must have received “notification of an investigation, litigation, regulatory proceeding or other government or civil action that might affect its compliance.” However, .FRL was not subject to any such proceeding at the time, and the procedure could not be used.



OUTSTANDING QUESTIONS

  1. Language in the preamble of Appendix C is similar but different from the GDPR.  What was the thinking in writing it this way?