@EXT: 2018-05 New Policy Proposal (Publication of Legal Address of Internet Number Resource Holder) - updating the proposal?

Hi everyone, All the comments exchanged in the list made me thinking a lot about the wording of this proposal. I have noticed that the lively discussion around the policy is bringing a lot of attention on the dichotomy between the individual (which I agree completely, should be protected in their fundamental rights, with provisions such as the GDPR and others), and the company/corporation. It seems to me so far that many of us would indeed support the idea of having the legal address published of companies, but having concerns about personal data. The aim of this proposal is indeed to focus on companies, not individuals, and even the smallest company has to be registered as such (if not for other reasons, for tax reasons). Individuals will be anyways protected by a hierarchically higher set of rules: the fundamental rights, such as those championed by GDPR for example. At this point I am asking whether you support a proposal, the clarifies that only the legal address of companies will be published, and that states clearly that individuals information will be protected? After all, the reasoning here is that if a resource holder is registered with a national company registry, they have a legal address which can be published. This legal address is usually publicly available anyhow and can be then validated by the RIPE NCC. Looking forward to hear the feedback to this idea for an amendment to the proposal. Sara ******************* DISCLAIMER : This message is sent in confidence and is only intended for the named recipient. If you receive this message by mistake, you may not use, copy, distribute or forward this message, or any part of its contents or rely upon the information contained in it. Please notify the sender immediately by e-mail and delete the relevant e-mails from any computer. This message does not constitute a commitment by Europol unless otherwise indicated. *******************

At this point I am asking whether you support a proposal, the clarifies that only the legal address of companies will be published
not particularly the contract is between the ncc and the registrant; not the community and the registrant. whois (not the irr, which is confuddled with it in the ripe registry) is useless and should die. randy

On Mon, 8 Oct 2018, Marcolla, Sara Veronica wrote:
Hi everyone,
Greetings,
All the comments exchanged in the list made me thinking a lot about the wording of this proposal. I have noticed that the lively discussion around the policy is bringing a lot of attention on the dichotomy between the individual (which I agree completely, should be protected in their fundamental rights, with provisions such as the GDPR and others), and the company/corporation. It seems to me so far that many of us would indeed support the idea of having the legal address published of companies, but having concerns about personal data. The aim of this proposal is indeed to focus on companies, not individuals, and even the smallest company has to be registered as such (if not for other reasons, for tax reasons). Individuals will be anyways protected by a hierarchically higher set of rules: the fundamental rights, such as those championed by GDPR for example.
Well, LIR addresses are already published on the RIPE NCC's website. LIR's customers addresses may not be part of whois.ripe.net... well... i know some LIRs tend to protect their customers identity, to prevent competitors to approach them with better contractual conditions (this is not the case of the LIR i work for, which is a NREN)
At this point I am asking whether you support a proposal, the clarifies that only the legal address of companies will be published, and that states clearly that individuals information will be protected? After all, the reasoning here is that if a resource holder is registered with a national company registry, they have a legal address which can be published. This legal address is usually publicly available anyhow and can be then validated by the RIPE NCC.
I see added value in "validation by the RIPE NCC", despite the natural cost this will bring... However, i wonder what should be the procedure if RIPE NCC finds that company X registers a new company Y in a different country/economy resorting to a "virtual office" address.
Looking forward to hear the feedback to this idea for an amendment to the proposal.
Good luck! Best Regards, Carlos
Sara *******************
DISCLAIMER : This message is sent in confidence and is only intended for the named recipient. If you receive this message by mistake, you may not use, copy, distribute or forward this message, or any part of its contents or rely upon the information contained in it. Please notify the sender immediately by e-mail and delete the relevant e-mails from any computer. This message does not constitute a commitment by Europol unless otherwise indicated.
*******************

Il 08/10/18 17:46, Marcolla, Sara Veronica ha scritto:
After all, the reasoning here is that if a resource holder is registered with a national company registry, they have a legal address which can be published.
Maybe the key to make everyone happy is the word "can" instead of "must". Why not make it optional? If companies are in good faith or they like the idea then they will use it, and they will also be happy to maintain the data. Otherwise it will be just a waste of time on another wrong/outdated/malicious dataset. How fun it is to check the validity of a validated address? Life is too short, right?
This legal address is usually publicly available anyhow and can be then validated by the RIPE NCC.
Duplicating data instead of referencing it breaks the first database design rule. Companies are forced by law to keep their chamber of commerce data up to date. THAT is the best source of information and it is readily available. Don't reinvent the wheel. This proposal is can of worms: - same data in many places is difficult to maintain and prone to errors - doesn't stop bad actors - quickly provides massive information to data harvesters and scammers In my opinion this proposal is not the right way to identify a resource holder the way you dreamt. It's not a elegant solution and in general I have a bad feeling about it, imagine a blunt tool that not only will make a poor job but also will bring a lot of frustration. Ok for me if it is optional, otherwise I'm against. Regards, -- Nik Soggia - TELNET S.r.l. Phone: +39-0382-529751 Via Buozzi, 5 - 27100 Pavia, Italy Fax: +39-0382-528074
participants (4)
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Carlos Friaças
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Marcolla, Sara Veronica
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Nik Soggia
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Randy Bush