Dear members,
Here is a short report on what was discussed on our latest working group's call on the 13th of September.
Work on the '
CCPA - PLA_CoC Mapping and Gap Analysis' document:
- Martim and Isabella finished the review of the gaps resolution and proposed solutions for the next steps.
- Row 169-170, provision goes beyond the GDPR controls. It is a CCPA provision which doesn't have a GDPR equivalent. It was recommended as a full gap. Martim agrees with amending the Glossary and suggests adding more content to the definition. Second option would be to add a footnote.
- Row 179, by Mark Vinkovits: the chairs re-phrased definition and need to add the definition of 'commercial purposes' to the Glossary. Martim suggest to change the definition of the processor and bring it closer to the definition that exists in the CCPA.
- Row 186 by Mark Vinkovits: Definition of device doesn't exist in GDPR. Martim suggested to include it and link to definition of personal data and add the deifinition of device.
- Row 189, by Mark Vinkovits: Amendment on the definition of profiling. The co-chair team suggests revision to the definition.
- Row 191, by Mark Vinkovits: The co-chairs made an amendment in the Glossary. Dual definition covers the provision.
- Row 220, by Mark Vinkovits: Include additional information of definition and add exceptions on what don't constitute 'selling' under the CCPA. Wherever it mentions 'controller' it means CSP.
- Row 227, by Paul Benedek: Row 179 captures 227.
- Rows 229-231 by Paul Benedek: Co-chairs propose to go by previous amendment and use the changes to WWP6 to capture changes. Certification in the DPA.
- Row 243 by Paul Benedek: Co-chairs suggest to add a reference to the unique identifiers and the definition of personal data, and add the definition of 'family' in the Glossary.
Action items:
- The co-chairs will revise the definition of row 189 and propose something different.
- Mark ( @Mark Vinkovits) to go through document and check if there are left suggestions by Martim unanswered on his behalf.
- Paul ( @Paul Benedek) to go through the suggestions made by the co-chairs in his rows.
- Martim ( @Martim Taborda Barata) is to ping the WG's participants to comments on the final solutions that they proposed on the gaps.
- Co-chairs will create a first draft for the amendment and share it with the working group for a short review. It may be an additional tab to the Code of Practice document and it will work as an add-on.
- Discuss on the next call how this amendment can be executed.
Next working group call: Tuesday, 11 October, at 17:00 CET / 18:00 EET/ 11:00 a.m. EST
url: https://zoom.us/j/346875696?pwd=d0Y5YlNDbmdldnY3UEJaTTYyci8vZz09 (Meeting ID: 346 875 696)
Kind regards,
Marina
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Marina Bregkou,
Senior Research Analyst,
CSA
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