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Apologies: James Bladel (RrSG) Alternates: Owen Smigelski (RrSG) |
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Notes/ Action Items EPDP Phase 2A - Meeting #15 Proposed Agenda Thursday 15 April 2021 at 14.00 UTC
Comments from team:
Guidance development
1) Consider adding reference to information requirements in relation to consent? 2) Consider making more specific that the registrant (data subject) needs to have an easy means to correct mistakes? 3) Consider adding a step that following Registrant confirmation that the registration does not include any personal data, the registrar should contact the provided contact details to confirm that no personal data is present. 4) Consider adding guidance that sufficient time must be provided for the Registrant (data subject) to respond to the verification request, but that there is no need to wait for an affirmative response, unless an email bounces (in which case the Registrar should not proceed with publication). 5) Consider adding that the Registrar should request the Registrant, if self-identified as legal person, to provide a company registration number. 6) Consider making more specific that at this stage the Registrar should ask whether Registrant (data subject) consents to publication of personal data? 7) Consider adding that, as an example, a Registrar could also use the company registration number to verify legal personhood. 8) Consider whether such a tool (to assess whether email addresses include an individual's name or appear to be generic) exists and/or is feasible? 9) Consider reference to this guidance/opinion from B & B
Action item #1: EPDP Team to review remaining 4 questions in the comparison document and provided responses to those questions by Monday 19 April. In addition, EPDP Team to identify any further questions that the EPDP Team should consider as a result of the Bird & Bird advice to address any potential inconsistencies or additional safeguards.
Action item #2: EPDP Team to review these questions in the latest version of the write up and provide input, preferably in the form of specific text to be considered by the EPDP Team by Monday 19 April. Consideration of question i. Whether any updates are required to the EPDP Phase 1 recommendation on this topic (“Registrars and Registry Operators are permitted to differentiate between registrations of legal and natural persons, but are not obligated to do so“);
Action item #3: EPDP Team to respond to questions outlined in the google doc in relation to the question of whether or not changes should be made to existing requirements by Wednesday 21 April and come prepared to the meeting on 22 April to provide a high level summary of the responses provided.
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