Hi Niall

On 02/06/2015 16:49, Niall O'Reilly wrote:

On Tue, 02 Jun 2015 14:36:21 +0100,
Athina Fragkouli wrote:

If the RIPE community wishes to have access to contact details of
individuals that were responsible for resolving operational problems in
the past, then the RIPE community must have a specific, explicitly
defined and legitimate purpose for it. If such a purpose is defined, the
RIPE NCC will proceed with investigating the conditions under which this
feature can be implemented in compliance with the Act. Implementation of
this feature may include prior consent of these individuals.

  Thanks, Athina.

  IIUC, if such a purpose as "maintaining a historical record" were
  defined, the relevant data subjects would have to opt in before
  their details could be included.  Is that it?

Two of the existing purposes partially cover this:

- Providing information about the Registrant and Maintainer of Internet number resources when the resources are suspected of being used for unlawful activities, to parties who are authorised under the law to receive such information.

- Providing information to parties involved in disputes over Internet number resource registrations to parties who are authorised under the law to receive such information.

These allow for the NCC to retain this information (maintain a historical record) for investigations or disputes that may arise in the future over historical resources. But neither allow for this historical information to be made publicly available in respect of personal data or (referring to my previous email) data used purely for the management of operational data.

cheers
denis


  ATB
  Niall