Hi Angel On Tue, 31 May 2022 at 15:31, Ángel González Berdasco via db-wg <db-wg@ripe.net> wrote:
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.
Yes GDPR does allow for consent. However in a database with widely distributed data entry, knowing that consent has been given, and not withdrawn, by each data subject is very difficult to confirm by the data controller. Also it would be necessary for each data subject to be fully informed of the potential consequences of publishing their personal data in an open, public database. Even if some natural persons want their details published in the RIPE Database, for whatever reasons, unless there is a purpose that clearly states the 'need' to do this, it is not a good idea to do it. There are too many unknowns between the data controller and some of the data subjects to be able to allow this with any degree of certainty for the data controller. cheers denis proposal author
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
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