Colleagues I received quite a lot of feedback at RIPE 84 on this policy proposal. This was mainly on two aspects, resource holders name and address and contacts. I will start with a summary of the views on contacts as this is the easier one to deal with. Contacts are listed in the RIPE Database to resolve issues. Currently these are technical, administrative, abuse, routing and DNS issues. They can also be listed for external services like RIPE Atlas and IRTs. Other issues or services may be added in the future. Contacts should only exist in the database if they are relevant to one of these defined reasons. Contacts listed for any other reasons should be removed. A contact needs to be contactable. The whole RIPE philosophy is built around email. So every listed contact must have a mandatory and working email address. This should be verified on entry into the database. Any other means of contact should be optional. These other means may have dedicated attributes like phone and fax. Or they can be added via remarks to include, for example, a URL for a web form, irc, a facebook group, or any other social media. Any of these other means may have dedicated attributes added if there is sufficient interest. These other means should also be verified on entry into the database, where technically possible. Contacts are for resolving immediate issues. They are not for receiving legal notices or arranging site visits. An address is therefore not needed and should be deprecated from any form of contact. Identifiable individuals are not needed for the defined purposes of contacts. All contacts should therefore be defined as business roles and only contain non personal data. Does this sound like a reasonable summary of contact details? cheers denis proposal author On Tue, 17 May 2022 at 11:03, denis walker <ripedenis@gmail.com> wrote:
Hi Cynthia and Peter
You both raise some interesting points and I will address them all in one email. Let's start with 'why' do we publish the name and address of resource holders. The RIPE Database is one of a set of 5 databases that collectively document the registration of all global internet resources. This is to offer to the public an open source of the 'who' is using internet resources. Only by offering this information openly can we have accountability at all levels of society. If this information is closed with restricted access then accountability can only be judged and enforced by lawful authorities.
So let's look in more detail at the consequences of open vs closed data. This only applies to the name and address details of resource holders who are natural persons as well as end users operating public networks with assignments. No other personal data should even be considered in this database.
In an open system the names and addresses of all internet resource holders and public network operators are published. In an ideal world all this data will be verified and accurate. This makes it easy for anyone who is following up on criminal activity or abuse on the internet to look up who is using a particular (block of) addresses. This is not only LEAs. Private organisations and individuals can also follow up abuse and take civil actions against the abusers.
In a closed system we don't publish names or addresses of natural people. The information will be held by the RIPE NCC or a member or a sub allocation holder, or ... This gives maximum privacy protection for natural persons, but causes problems for anyone trying to address criminal activities or abuse on the internet. This arrangement can be further manipulated by the bad actors to hide their tracks. Suppose a natural person in country A becomes a member. Their details are not published. They sub-allocate to a natural person in country B who assigns to a natural person in country C. None of their details are published. If this assignee is an abuser, an LEA, or other organisation, has to get a court order in the Netherlands to get the details of the resource holder in country A from the RIPE NCC. Then they need a court order in country A to get the details of the sub allocation holder. Then they need a court order in country B to get the details of the assignee. If we go down this closed system route we may have to look at who has a right to this information (which is currently public) and how....but that is outside the scope of this policy proposal.
Another option, where a resource holder is a natural person, is to 'require' them to have an official, legal address such as an accountant or lawyer office, with their consent to publish that (non personal) address.
Having a simple rule like 'we don't publish names or addresses of natural persons' is easier to apply and less error prone. But we are turning the RIPE Database into more like a domain registry where lots of details are hidden from public view. Does this affect the usefulness of the RIPE Database as a public registry?
I think it is a good idea to extend the scope of this policy to include anywhere that the RIPE NCC publishes personal details of members. So it would include the web pages where members are listed.
cheers denis
On Fri, 13 May 2022 at 00:56, Cynthia Revström via db-wg <db-wg@ripe.net> wrote:
Hi,
I am generally in support of this policy, however I do wonder why publish legal names of individuals in the cases of natural persons holding resources?
Like why can't it just be some alias and the real name needs to be requested from the RIPE NCC by court order or whatever would be required for physical addresses under this proposal.
While my name is a bad example, there are plenty of names that are extremely common, and if all that is published is the name and country, is it really all that useful? It is not like knowing that it is someone in the United States with the name "Joe Smith" is particularly useful on its own to know who it is. But on the other hand in such cases it is not a big privacy problem I suppose.
However with a name like mine it is a privacy concern as my name is not exactly common.
I would like to hear what the reason would be for requiring this to be published if it is either kinda pointless information or still a big privacy issue.
Also I have a kinda Sweden-specific question about the following part (from 1.0 Organisations):
personal address for the organisation which is already in the public domain in a national, public, business registry.
In Sweden there are multiple private organizations that publish home addresses for almost everyone in the country by combining some quirks of the freedom of the press act and government transparency. Would this count according to that, and as such would you say it is okay to publish the personal addresses for almost everyone in Sweden? The government doesn't directly publish this information, people have no right to demand to be excluded but it is still public. The important thing here though imo is that these websites generally are a lot harder to scrape than the RIPE Database.
Also what if it was an address that was kinda public but you had to create an account and agree to not re-publish it elsewhere, would that make it okay or not okay to publish? Or what if that address is published somewhere, but not linked to that person's name, maybe it is linked to some unrelated legal entity that is on the same address, would that make it okay to publish?
I think it would be a lot easier to just say that personal addresses should never be published. Just because it is already somewhere on the internet doesn't mean that the RIPE Database has to spread it further.
-Cynthia
On Tue, May 10, 2022 at 11:29 AM Angela Dall'Ara via db-wg <db-wg@ripe.net> wrote:
Dear colleagues,
A new RIPE Policy proposal, 2022-01, "Personal Data in the RIPE Database" is now available for discussion.
The goal of this proposal is to allow the publication of verified Personal Data in the RIPE Database only when they are justified by its purpose.
You can find the full proposal at: https://www.ripe.net/participate/policies/proposals/2022-01
As per the RIPE Policy Development Process (PDP), the purpose of this four week Discussion Phase is to discuss the proposal and provide feedback to the proposer.
At the end of the Discussion Phase, the proposer, with the agreement of the WG Chairs, will decide how to proceed with the proposal.
The PDP document can be found at: https://www.ripe.net/publications/docs/ripe-710
We encourage you to review this proposal and send your comments to db-wg@ripe.net before 8 June 2022.
Kind regards,
Angela Dall'Ara Policy Officer RIPE NCC
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