- db-wg - mailman.ripe.net

Re: [db-wg] NWI-13 Geofeed Legal Analysis
by Lutz Donnerhacke 28 Jul '22

28 Jul '22

So the geofeed attribute will be deleted from the database? Do you have a timeframe for this implementation? Von: db-wg <db-wg-bounces(a)ripe.net> Im Auftrag von Maria Stafyla via db-wg Gesendet: Donnerstag, 28. Juli 2022 13:33 An: db-wg(a)ripe.net Betreff: [db-wg] NWI-13 Geofeed Legal Analysis Dear colleagues, Following the legal update we provided on NWI-13: Geofeed at the DB WG session at RIPE 84, here is our analysis in case further discussion on this topic is needed. Executive Summary: - The RIPE Database is meant to contain specific information for its documented purposes. - Information inserted in the geofeed attribute could in some cases qualify as personal data. - The current purposes could explain geolocation information to be inserted only for ‘scientific research into network operations and topology’. - This purpose does not justify the processing of personal data; therefore restrictions had to be put in place to avoid the processing of unnecessary personal data. - The restrictions are now implemented based on the status of the registration. - If the purposes of the RIPE Database have changed in the meantime, this should be established via the community processes and documented. In that case we will re-evaluate the situation and the need for restrictions. Until then, the restrictions remain necessary. Legal Analysis: The RIPE Database is meant to contain specific information for the purposes that are defined in the RIPE Database Terms and Conditions. In terms of the _personal data_ inserted in there, the purpose that justifies its publication is to facilitate the coordination of network operations for the smooth and uninterrupted operation of Internet; this purpose explains why contact details of resource holders or their appointed contact persons are required. Before any new type of personal data is permitted to be inserted in the RIPE Database, we must evaluate if their processing is required for the purposes already defined and their processing can be considered in line with the basic personal data processing principles. Although it is the responsibility of the party inserting personal data to ensure that they have the appropriate legal grounds before doing so, the RIPE NCC has also shared responsibilities with regards to the personal data in the RIPE Database. This is because the RIPE NCC is the party that is making the RIPE Database available and implements the instructions given by the RIPE community. As mentioned in the Legal Review Impact Analysis, if the geofeed attribute is inserted for registrations of assignments that are reasonably assumed to be related to one individual user, then the attribute will be considered as containing personal data and GDPR will apply. This is why we have proposed to implement restrictions. These restrictions are essential to avoid any processing of personal data that is not required or necessary for the currently defined purposes of the RIPE Database and to limit the RIPE NCC's liability as a party with shared responsibilities in relation to the personal data inserted in the RIPE Database. Regarding the _(non-personal) data _inserted in the RIPE Database, it is also paramount that only data that is needed for the defined purposes of the RIPE Database is inserted. According to the RIPE Database Terms and Conditions, introducing the geofeed attribute (with restrictions) would be considered in line and acceptable to be used only for scientific research into network operations and topology (see Art. 3). We also understand that the purposes the RIPE Database must fulfil are not static but evolve over time. The RIPE Database Requirements Task Force has recently concluded its work and, with regard to geolocation, it has established that, although there is an active user group for geolocation data, geolocation itself is not an objective that the RIPE Database should fulfil. If the community's interests have changed since then and it is now agreed that geolocation is one of the purposes the RIPE Database must fulfil, this should be decided via the community's processes and reflected in the RIPE Database Terms and Conditions. In line with the data management principles proposed by the RIPE Database Requirements Task Force, it would be prudent to approach this issue holistically, taking into account that other geolocation information is already provided in the RIPE Database (i.e. geoloc, country code attributes in ORG and resource objects). On the basis of a new purpose for the geolocation information, we could then reassess the situation to understand whether the restrictions on the geofeed attribute are still necessary or whether it is justified to process personal data for this purpose. Kind regards, Maria Stafyla Senior Legal Counsel RIPE NCC

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IRT object postal address
by denis walker 24 Jul '22

24 Jul '22

Colleagues During the conversion we had some time ago about contacts we concluded that no one is going to visit a contact or post them a letter. The IRT object also had a mandatory address attribute that is defined in the documentation as: "This is a full postal address for the business contact represented by this irt object." Does anyone think we actually need a postal address for a contact for a CSIRT team? Cheers denis

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Re: [db-wg] IRT object postal address (denis walker)
by William Weber 22 Jul '22

22 Jul '22

As cybercriminal i wholeheartedly support the idea of removing all personal data from the RIPE DB. That would make my life so much easier. -- William On Fri, Jul 22, 2022 at 12:00 PM <db-wg-request(a)ripe.net> wrote: > Send db-wg mailing list submissions to > db-wg(a)ripe.net > > To subscribe or unsubscribe via the World Wide Web, visit > https://lists.ripe.net/mailman/listinfo/db-wg > or, via email, send a message with subject or body 'help' to > db-wg-request(a)ripe.net > > You can reach the person managing the list at > db-wg-owner(a)ripe.net > > When replying, please edit your Subject line so it is more specific > than "Re: Contents of db-wg digest..." > > > Today's Topics: > > 1. Re: IRT object postal address (denis walker) > > > ---------------------------------------------------------------------- > > Message: 1 > Date: Thu, 21 Jul 2022 15:41:58 +0200 > From: denis walker <ripedenis(a)gmail.com> > To: "Ronald F. Guilmette" <rfg(a)tristatelogic.com> > Cc: Database WG <db-wg(a)ripe.net> > Subject: Re: [db-wg] IRT object postal address > Message-ID: > < > CAKvLzuE+RoNgGXL8TU3r4E5dOtOd3uweB9UzFJhgnOmpBruU+g(a)mail.gmail.com> > Content-Type: text/plain; charset="UTF-8" > > Ronald > > (For those who don't read long emails...) The bottom line is that this > proposal recommends to remove postal addresses of contacts, not > publish the 'full' postal address of natural persons holding > resources, replace personal data with business data and generally > bring the contents of the RIPE Database into line with the defined > purposes. > > --- > Now to answer Ronald's points... > > You have your own (hidden) agenda Ronald, which is fine. But don't > expect everyone to fall into line behind you. Most people know your > tactics. Repeat the same nonsense and conspiratorial theories over and > over and over again until people believe they must be true. You lock > onto a phrase or even a word and create an entire fear mongering story > around it. Then keep asking the same irrelevant questions and > demanding answers. This is not how to have a professional discussion, > it is a Trump/Johnson style campaign. > > Let's kill off some of your fear stories. I am NOT against > accountability, NOT helping cybercriminals, NOT proposing anonymity, > NOT obfuscating half the database, NOT proposing secrecy and NOT > avoiding transparency. > > As for GDPR, the only person obsessed with it is you Ronald. It is not > even mentioned in the proposed policy text. You use it to confuse all > discussions on the content of the database. GDPR is only one of the > factors concerning the content of the RIPE Database. There are defined > purposes for the database. As the RIPE Database Task Force pointed > out, we should minimise the amount of data needed to fulfil those > defined purposes. That is the overriding principle governing what > should go into the database and what remains in the database. > > Most people did accept that in order to resolve internet operational > issues (one of the main purposes of the database) no one is going to > visit or post a letter to a contact in the RIPE Database. Therefore > contacts don't need postal addresses. Whilst you may feel there is a > need for a postal address for a contact for an IRT object, as Nick > said, the opinions of CSIRT teams are more relevant. > > You have said yourself many times that the database is full of > garbage. When you demand irrelevant data and force people to enter > information they prefer not to provide which is not even covered by > the database purposes, you increase the chances of some people > entering false or misleading information. The only 'crusade' I am on > is to bring the contents of the RIPE Database into line with the > minimum information required to fulfil the defined purposes of the > database and any legal requirements. We can have a healthy discussion > on interpretations of that minimum information, but we should not be > arguing over the principle. Forcing people (with mandatory attributes) > to enter 'interesting' but not relevant information leads to a corrupt > and diluted database that is less useful to anyone. Even optional > attributes that are not relevant, dilute the important information. > > You can wish for any information you like to be in the RIPE Database > Ronald, but if it is not essential for the defined purposes, it is not > going to be there. Feel free to propose your own policies to change > the purposes of the database and store certified photos of all > contacts and their families if you believe that is necessary for your > use of the database...or set up your own database. > > cheers > denis > proposal author > > On Thu, 21 Jul 2022 at 06:01, Ronald F. Guilmette via db-wg > <db-wg(a)ripe.net> wrote: > > > > In message < > CAKw1M3MEHHC63+BfS7P365F0Cw6hcGuOKKq0ZaTS+evtdiZDoQ(a)mail.gmail.com> > > =?UTF-8?Q?Cynthia_Revstr=C3=B6m?= <me(a)cynthia.re> wrote: > > > > >> *) Why is the hiding of information even a priority? > > > > > >Hiding information is good from a privacy standpoint so you have to > > >weigh the benefit of having the data public against the privacy > > >implications of publishing it. (and consider any potential legal > > >issues/requirements) > > > > Transparency is good from an accountability standpoint. And in my > opinion, > > we have far far too little accountability on the Internet. Practically > > every day now one can find stories about "hackers" and "cybercriminals" > > and everyone just shrugs and goes back to work as if this is the way that > > thing have to be, or that they are supposed to be. > > > > My position is simple: If youy want to be anonymous, then get yourself a > > pseudonym account on Twitter, or Facebook, or YouTube, or whatever, and > > then blast away. Or alternatively, get yourself a domain name with all > > of the WHOIS data redacted and then arrange wweb site hosting for that, > > either on one IP of one hosting company, or several. But somewhere up > > the chain there needs to be accountability, always. It is *not* a God- > > given right to have an IP address block or an ASN. It is a privilege. > > And that special privilege should be reserved for those who are willing > > to be held accountable for what goes on upon their networks. > > > > You and Denis are trying to _remove_ accountability from the equation, > and > > I remain steadfast in asserting that this will only benefit criminals. > > > > >> *) Are these deliberate obfsucation steps still being justified on > the > > >> basis of GDPR, or do you now accept as fact that GDPR is irrelevant in > > >> the context of the RIPE data base, and that it does not currently > compel > > >> RIPE to make any changes to the public WHOIS data base whatsoever? > > > > > >Denis has already mentioned in an email regarding 2022-01 that he will > > >not address any more GDPR issues until there has been a legal review > > >as many of us are not lawyers. > > > > I'm sure that I saw someone post here quite recently that he had checked > with > > RIPE legal already, and had already been assured that RIPE is _not_ > facing > > any current or imminent legal jeopardy with the status quo as it now > exists, > > either in relation to GDPR or in relation to any other applicable law or > > regulation. If you need me to do so, I will find that posting in the > archives > > and I'll copy it here. > > > > >While I can't speak for Denis, you have not convinced me that GDPR is > > >somehow irrelevant > > > > I don't see how or why it should be incumbant upon either me or anyone > else > > to persuade either you or Denis that no change needs to be made. You > and he > > are putting forward and supporting this proposal for a _change_ in the > > current status quo. It is thus necessary for you folks to make a > persuasive > > case that a change _is_ needed, rather than for me or anyone else to > make a > > case that it isn't. > > > > >> *) If the goal is to hide information, then why not just take the > entire > > >> RIPE WHOIS data base offline and hide the whole thing behind some > sort of > > >> permission-wall that can only be pierced with a legal warrant? > > >> > > >> (That last question is, of course, the essential point, since that > endpoint > > >> seems rather clearly to be the direction in which this is all headed.) > > > > > >This question is not really an "essential point" in my opinion as > > >there is a big difference between hiding postal addresses and hiding > > >abuse email addresses and route(6) objects. > > > > You are doing just what Denis has done so far in relation to this whole > > thing... You are evading the question. If transparency is "bad" and > > secrecy is "good" then why not take that general principal to its final > > and logical conclusion? Why not just take the whole WHOIS data base > > offline entirely? > > > > It's a simple question. I'd like to see either you or Denis answer it, > > rather than evade it. > > > > > > Regards, > > rfg > > > > -- > > > > To unsubscribe from this mailing list, get a password reminder, or > change your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/db-wg > > > > ------------------------------ > > Subject: Digest Footer > > -- > > To unsubscribe from this mailing list, get a password reminder, or change > your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/db-wg > > > ------------------------------ > > End of db-wg Digest, Vol 131, Issue 14 > ************************************** >

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New Version of the RIPE Database Documentation is Available
by Edward Shryane 20 Jul '22

20 Jul '22

Dear Colleagues, The DB team are pleased to announce that a new version of the RIPE Database documentation is now available: https://apps.db.ripe.net/docs/ We are using a common framework that we have across many RIPE NCC technical services, such as RIPEstat, RIPE Atlas, RIS and RIPE IPmap. This framework has some advantages: * Allows us to use a more modern layout that is common across these services. * A built-in search field is now available at the top of each page. * The documentation is stored in Markdown format, making it easier for the team to make changes, and accept outside contributions. * We are now able to deploy changes together with a Whois or DB web application release. Under the hood, the new documentation uses the VuePress framework: https://vuepress.vuejs.org If you prefer not to use JavaScript, or to print or save the entire documentation, it is also available on a single page: https://apps.db.ripe.net/docs/entire-documentation-(HTML) The documentation contents are published on GitHub, please create a pull request or an issue to contribute improvements: https://github.com/RIPE-NCC/ripe-database-documentation Finally, we plan to migrate (redirect) the existing RIPE Database Documentation pages to the new site. https://www.ripe.net/manage-ips-and-asns/db/support/documentation/ripe-data… Regards Ed Shryane RIPE NCC

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Impact Analysis for Removing Whois Object Tags
by Edward Shryane 14 Jul '22

14 Jul '22

Dear Colleagues, Following is an impact analysis for removing Whois object tags from the RIPE database. Please reply with any questions or comments. Whois object tags was added as a beta feature in 2013: https://labs.ripe.net/author/kranjbar/presenting-object-metadata-in-the-rip… All resources were tagged at that time (inetnum, inet6num and aut-num), but the data was never updated since then. We plan to remove this feature in the next Whois release, both the query flags and tag data. This will impact the RIPE database in the following ways. (1) Tag Data The following tags exist: RIPE Database: RIPE-REGISTRY-RESOURCE and RIPE-USER-RESOURCE AFRINIC Mirror Database: AFRINIC-USER-RESOURCE and AFRINIC-REGISTRY-RESOURCE APNIC Mirror Database: APNIC-USER-RESOURCE and APNIC-REGISTRY-RESOURCE ARIN Mirror Database: ARIN-REGISTRY-RESOURCE and ARIN-USER-RESOURCE Once support for tags are removed, all tag data will be removed from all databases. (2) Whois Query Flags Four query flags were added to support tags: % --no-tag-info % Switches off tagging information. % % --show-tag-info % Switches on tagging information. % % --filter-tag-include % Show only objects with given tag(s) % % --filter-tag-exclude % Do not show objects with given tag(s) Tags are not returned in port 43 queries by default. I have not found these flags in recent query logs for port 43, i.e. they are not used. Once support for tags are removed, an error will be returned if they are used in a query, e.g. % Invalid option: --no-tag-info % %ERROR:111: invalid option supplied % % Use help query to see the valid options. (3) REST API The query flags for tags are not supported by the Whois REST API. If any are included in the "flags" query parameter in a search, a 400 Bad Request is returned. However tags are returned by the Whois search and lookup endpoints by default, if present, within the /whois-resources/objects/object/tags/tag element. Once support for tags are removed, they will not be returned by the Whois REST API. (4) Web Application Query and Lookup The DB web application query and lookup pages uses the Whois REST API. However tags are not displayed if returned by the REST API. (5) Database Dump and Split Files The nightly database dump and split files contain tags as a comment following some resources, e.g. % Tags relating to 'AS3333' % RIPE-REGISTRY-RESOURCE Once support for tags are removed, these comments will not appear between RPSL objects. Regards Ed Shryane RIPE NCC

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Non-RIPE INRs in an Example returned by RIPE Whois DB Query Service
by Sylvain Baya 11 Jul '22

11 Jul '22

Dear DB-WG, Hopefully this email finds you in good health! While exploring some RIPE Whois DB classes [1], i discovered some examples, i thought to be inappropriate [3]. ...i would like to draw to your attention, on the presence of some INRs [2] managed [3] by an other RIR, which appear in content returned when the RIPE Database is queried [2]. __ [1]: <paste1> cacty@shalom:~$ whois -h whois.ripe.net -t route | grep --regexp="^holes" --after-context=0 holes: [optional] [multiple] [ ] </paste1> [2]: <paste2> cacty@shalom:~$ whois -h whois.ripe.net -v route | grep --regexp="^holes$" --after-context=11 holes Lists the component address prefixes that are not reachable through the aggregate route(perhaps that part of the address space is unallocated). An address prefix is represented as an IPv4 address followed by the character slash "/" followed by an integer in the range from 0 to 32. The following are valid address prefixes: 128.9.128.5/32, 128.9.0.0/16, 0.0.0.0/0; and the following address prefixes are invalid: 0/0, 128.9/16 since 0 or 128.9 are not strings containing four integers. </paste2> [3]: <https://www.iana.org/assignments/ipv4-address-space/> Maybe it's the only description which contains such non-RIPE INRs; other than of RFC 5737 [4]... __ [4]: <https://www.iana.org/assignments/iana-ipv4-special-registry/> ...but perhaps someone, from the Staff, should check? Thanks. Shalom, --sb. -- Best Regards ! baya.sylvain [AT cmNOG DOT cm] |cmNOG's Structure <https://www.cmnog.cm/dokuwiki/Structure>|cmNOG's Surveys <https://survey2.cmnog.cm/> Subscribe to the cmNOG's Mailing List <https://lists.cmnog.cm/mailman/listinfo/cmnog/> __ *#‎LASAINTEBIBLE‬|‪#‎Romains15‬:33«*Que LE ‪#‎DIEU‬ de ‪#‎Paix‬ soit avec vous tous! ‪#‎Amen‬!*»‪#‎MaPrière‬ est que tu naisses de nouveau. #Chrétiennement‬«*Comme une biche soupire après des courants d’eau, ainsi mon âme soupire après TOI, ô DIEU!*» (#Psaumes42:2)*

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2022-01 personal data in the "descr:" attribute
by denis walker 06 Jul '22

06 Jul '22

Colleagues Up to now we have focused mostly on member's personal data. But this isn't only about members. The database contains lots of personal data for end users as well. The INET(6)NUM objects have a "descr:" attribute. This has been used extensively for (personal) data about end users, mostly name and address, but maybe also phone numbers. There may well be more of these who are natural persons than members. There are 4.2m INETNUM objects in the database. So the scale of the problem may be far higher here. This is also a more complicated problem. The data is entered by resource holders and possibly multiple levels of sub-allocation holders. The issue of informed consent is hard to judge. Consent may be in the small print of a contract and it may not be clear to the data subject just what they are consenting to. The RIPE Database may contain the home address of many end users without them knowing what this database is or what the consequences are of publishing their personal data in it. This data is also unstructured, unverified, undefined free text. As with member's data there are pros and cons regarding the usefulness of this data. Also the defined purposes of the database cover adding the name and phone number of an end user as part of the public registry, but again not their home address. With the data being undefined, it is not clear what any address relates to. We don't know what address the resource holder asked for or what address the end user supplied. The address, therefore, has no meaning to anyone reading this data. So the question we need to discuss is what do we do with this data in the "descr:" attributes? Perhaps I can start the discussion with a suggestion. First of all we should never overload free text attributes with structured data. So if we want to add a name and address to resource objects we should include user name and address attributes. If we are going to add a new address field we should break it down into a structured set of address attributes, as all addresses should have been from the start. Maybe a phone and/or email attribute is also needed, keeping in mind most end users don't usually have an ORGANISATION object. Any new attributes can all be optional, as it is by choice that resource holders currently add any such data into the "descr:" attributes. The same rules would apply to this data as we have discussed with the members' data. Phone and email must be business data and not personal and they will be verified. (I will explain more about verification in response to Leo's email.) Name may be personal if the end user is a natural person. In that case any optional address added must not be more specific than country and region. Another possible solution could be to optionally create an ORGANISATION object for end users. Either way, this data should not be in the "descr:" attribute. Most of this can be discussed later with the implementation details. What is really important as far as this policy proposal is concerned is the recognition that the same principles of processing personal data will be applied to end users as it is to members, regardless of what objects the data is stored in. cheers denis Proposal author

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Thoughts on 2022-01
by Leo Vegoda 01 Jul '22

01 Jul '22

Hi, Thank you for producing this proposal. It's important to regularly review policy and implementation to ensure we are meeting our legal responsibilities. Parts of the text in this proposal are clear and easy to interpret. For example section 3.0 on Notifications is well written. Other parts are highly ambiguous. The text as written would just lead to disputes. For example, "Email addresses added as contact details and all phone and fax numbers entered into the RIPE Database must be verified." Who must verify them, what must they verify, and when should this happen? Is this just a check that the contact information is syntactically correct? Or is this a check that a fax machine is active and used by the organization listed alongside it? It would be helpful to clearly separate the sections defining a principle from those defining an implementation. The text on verification and compliance is so ambiguous that it's not possible to understand what an implementation would look like. Kind regards, Leo Vegoda

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2022-01 v2 Personal Data in the RIPE Database
by Cynthia Revström 29 Jun '22

29 Jun '22

Hi db-wg, I just want to say that I mostly support the current proposal of 2022-01 (v2). I would prefer it if the following section was reworded in some way to make it more clear how the full home address is never justified and how the default should be no address at all for individuals. Also I think it should be changed to assume that any address an individual is operating from is a home address unless the individual themselves clearly say that it is not a home address. I would still support it in its current form without these changes but I would strongly prefer if these were made to prevent any confusion or ambiguity. (this section is part of 1.0 Organisations) <quote> The name of the organisation (which may be the personal data of a natural person) holding an Internet resource or managing part of an Internet resource, for example a sub-allocation, or using a block of addresses, is an essential part of the public registry. This identification is one of the principal purposes of the database. Any valid address could be helpful. Different types of addresses can be considered including postal addresses. The name and address of a natural person holding or using a resource and operating from a home address are the only personal data that can be justified to be published in the RIPE Database, provided there is documentary evidence held by the RIPE NCC, or a sponsoring LIR, or any resource holder that registered the subject’s details in the RIPE Database, that the natural person has consented to their name and address being published in this public registry. This consensual identification is a requirement of the public registry for holding an Internet resource or managing or using part of an Internet resource. A postal address may optionally be added by the resource holder or manager. Where the resource holder, manager or user is a natural person, the parts of any type of address more specific than country and region must not be entered in any object attribute. </quote> -Cynthia

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Re: [db-wg] Request for the correct review of document link
by Christian Nzhie 29 Jun '22

29 Jun '22

> > Good morning folk, I was reading this archive on the folowing link > https://www.ripe.net/ripe/mail/archives/db-wg/2022-June/007459.html > and I saw this > > The PDP document can be found at:https://www.ripe.net/publications/docs/ripe-710 > > However, when I click on the above link to review the proposal, I am > seeing the following red notice: This document is obsoleted by ripe-781 > <https://www.ripe.net/publications/docs/ripe-781> > So, please, kindly provide the correct link of version 2 under review... > Thanks in advance... > Christian Nzhie. >

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