In the case where UMA might be used for something other than personal data, would it make sense to have a totally different CommonAccord framework with RO = some other kind of Principal? I still have this idea that some UMA technical framework somewhere will find it valuable to build in a claims-based payment system.

On 10 Oct 2015, at 8:46 AM, Neiditz, Jon <JNeiditz@kilpatricktownsend.com> wrote:

This is INCREDIBLY important work that Jim is now doing, for trans-Atlantic trade, for the future of privacy, for UMA and for VRM, and Jim, the model clauses have proven the PERFECT vehicle for Common Accord. I’m so sorry that I missed some of yesterday’s call (literally passing out due to a pretty sleepless week, but maybe the minutes don’t need to so reflect), but let me make up for it by giving a preliminary, simple, provocative response to Eve’s email of last night. Under the model clauses:

RO = Data Subject
RS = Controller, Processor AND Subprocessor (AKA Exporter/Importer)
AS = NOBODY yet, which is why the Data Subject’s rights are all third party beneficiary rights. But an AS would authorize sharing with RS’s offering model clauses or modifications thereto. Which is why UMA can now extend EU privacy to people around the world (a lot of bridges, if that was what Scott meant when I was passed out).

D’Accord?

Jon Neiditz
Kilpatrick Townsend & Stockton LLP
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