Formal opinions would be helpful for people who feel the need for air cover
:-)

--Kurt

On Sat, Mar 17, 2018 at 11:11 AM, Ian Levy <[email protected]> wrote:

>
>    - re privacy - the fact that someone with authority (over the domain)
>    has requested said reports suffices for GDPR legal/consent coverage
>
> IANAL, but that’s my understanding as well. If it would be helpful, I can
> get a formal legal opinion and a statement from the UK Information
> Commissioner’s Office.
>
>
>
> Ta.
>
>
>
> I.
>
>
>
> --
>
> Dr Ian Levy
>
> Technical Director
>
> National Cyber Security Centre
>
>
>
> Staff Officer : Kate Atkins, [email protected]
>
>
>
> *From:* dmarc <[email protected]> *On Behalf Of *Kurt Andersen (b)
> *Sent:* 17 March 2018 09:41
> *To:* Steven M Jones <[email protected]>
> *Cc:* [email protected]
> *Subject:* Re: [dmarc-ietf] Agenda for IETF 101 DMARC session
>
>
>
> On Fri, Mar 16, 2018 at 10:47 AM, Steven M Jones <[email protected]> wrote:
>
> On 3/15/18 10:19 AM, Kurt Andersen (b) wrote:
>
>
>
>    - Creating a diagnostic report that would have some additional
>    information (such as sending address) and URLs without going quite as far
>    as a forensic report - so something between the aggregate and forensic
>    levels
>
>
> I'm probably missing something, but -- aren't email addresses usually
> classed as PII in the EU, whether they're sending or receiving at the
> moment? Seems to me it would run afoul of the privacy regs that tend to
> rule out forensic reports in certain jurisdictions...
>
> Maybe there's a batch/aggregate angle vs.  per-message that helps avoid
> that concern? Would time and URLs alone be useful enough to warrant the
> effort and expense?
>
>
>
> There are two aspects to this -
>
>    1. batching (lightens the load for reporting receivers), and
>    2. re privacy - the fact that someone with authority (over the domain)
>    has requested said reports suffices for GDPR legal/consent coverage
>
> --Kurt
>
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