FINAL VERSION SUBMITTED (IF RATIFIED)
The final version to be submitted, if the draft is ratified, will be placed here by upon completion of the vote.
FINAL DRAFT VERSION TO BE VOTED UPON BY THE ALAC
The final draft version to be voted upon by the ALAC will be placed here before the vote is to begin.
DRAFT SUBMITTED FOR DISCUSSION
The first draft submitted will be placed here before the call for comments begins. The Draft should be preceded by the name of the person submitting the draft and the date/time. If, during the discussion, the draft is revised, the older version(S) should be left in place and the new version along with a header line identifying the drafter and date/time should be placed above the older version(s), separated by a Horizontal Rule (available + Insert More Content control).
With regard to recommendation #1 purpose 2, which the board did not adopt and as this purpose was initially a place holder for further review in phase 2. The ALAC would like to make a proposal in relation to the purpose, taking into consideration the board's rational for not adopting it, the European Council (EC) comments on the team's final report and the previously provided guidance by the European Data Protection Board (EDPB). We suggest replacing purpose two of recommendation one by " Serving the public interest by maintaining the security, stability and resiliency of the DNS in accordance to ICANN's mission and bylaws".
The rationale behind our proposal is that all purposes should strictly be ICANN purposes, moreover "enabling responses to lawful data disclosure requests" is not a purpose but rather a processing activity.
The aforementioned purpose will need to be analyzed just as we did with all the other purposes in order to determine the processing activities associated with it. The lawful disclosure to relevant third parties as well as to ICANN if requird would result as a processing activity required to satisfy the purpose.