• The EPDP Team held its F2F meeting from Monday, 24 September – Wednesday, 26 September in ICANN Org’s Los Angeles office. The primary focus of the meeting was to answer specific charter questions related to the lawful purposes for processing gTLD registration (WHOIS) data, and those related to the identification of the specific data elements that are collected, redacted, and disclosed to third parties.

  • The Team began with the goal of defining the set of lawful purposes for processing domain registration data. The Team built upon its previous work in identifying potential lawful purposes for processing registration data and the relevant actors associated with each potential purpose, e.g., ICANN, registry operators, registrars. The Team deliberated on the draft purposes, and following tentative agreement on those, engaged in an iterative exercise to discuss the specific data elements associated with each draft purpose. 

  • As we often did throughout the three days, the Team worked in small groups to go through the exercise of identifying relevant data elements, as well as answer questions related to the lawfulness of processing. Some of the questions the Team discussed included:
  • who are data controllers, joint controllers and processors
  • whether proposed data processing purposes are lawful as tested against GDPR and other laws
  • what is the legal basis for each data processing purpose
  • when is data disclosure required to achieve a legitimate purpose

  • Thanks to the initiative of Thomas Rickert and Farzaneh Badii, we created worksheets that captured: the data sets collected, the legal bases for processing data, and GDPR tests for lawful data processing. These worksheets are an important output of the face-to-face meeting; the content of which will now be considered for inclusion in the Initial Report.

  • The facilitators helped to steer to deliberations, following the plan, and received wide support from the EPDP team for their approach despite some concerns expressed in the beginning. The EPDP team made steady progress during the F2F meeting and has follow-up actions for the coming weeks toward Barcelona meeting.