[db-wg] 2022-01 Resource holders identity

30-05-2022 a las 13:17 +0200, denis walker writes:
> If no one is able to present the public interest case for publishing
> the name and address of natural persons holding resources then the
> privacy case takes priority. If we cannot justify publishing this
> personal information based on the purposes, then the GDPR says very
> clearly that we must not publish it. All personal details of natural
> persons holding resources will have to be removed from the database
> or hidden from public view. This will also apply to assignments as
> well.
> There are many assignments with name and full address details of
> natural persons in the "descr:" attributes. We will have to remove
> the "descr:" attributes where the assignee is a natural person or
> hide them from public view.

Please note that GDPR has the concept of processing based on consent.
It might not be necessary to remove them. And some of those affected,
may want them to stay published.

I agree, however, that *not* publishing the home address of those that
hold a resource as a natural person is probably a good idea.

Regards

-- 
INCIBE-CERT - Spanish National CSIRT
https://www.incibe-cert.es/

PGP keys: https://www.incibe-cert.es/en/what-is-incibe-cert/pgp-public-keys

====================================================================

INCIBE-CERT is the Spanish National CSIRT designated for citizens,
private law entities, other entities not included in the subjective
scope of application of the "Ley 40/2015, de 1 de octubre, de Régimen
Jurídico del Sector Público", as well as digital service providers,
operators of essential services and critical operators under the terms
of the "Real Decreto-ley 12/2018, de 7 de septiembre, de seguridad de
las redes y sistemas de información" that transposes the Directive (EU)
2016/1148 of the European Parliament and of the Council of 6 July 2016
concerning measures for a high common level of security of network and
information systems across the Union.

====================================================================

In compliance with the General Data Protection Regulation of the EU
(Regulation EU 2016/679, of 27 April 2016) we inform you that your
personal and corporate data (as well as those included in attached
documents); and e-mail address, may be included in our records 
for the purpose derived from legal, contractual or pre-contractual
obligations or in order to respond to your queries. You may exercise
your rights of access, correction, cancellation, portability,
limitationof processing and opposition under the terms established by
current legislation and free of charge by sending an e-mail to
dpd at incibe.es. The Data Controller is S.M.E. Instituto Nacional de
Ciberseguridad de España, M.P., S.A. More information is available
on our website: https://www.incibe.es/proteccion-datos-personales
and https://www.incibe.es/registro-actividad.

====================================================================