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<p>Hi everyone,</p>
<div class="moz-cite-prefix">On 4/16/19 05:18, ripedenis--- via
address-policy-wg wrote:<br>
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<div>Colleagues</div>
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<div>Someone has kindly referred me to the conversation you had
last November on this same paragraph 6.2. It's not surprising
that there is some reluctance to discuss it again. BUT this is
a different discussion. Last time you focussed on defining
what type of network needs to be separately registered in the
RIPE Database. I want to discuss the next step from that. Once
you have decided a type of network needs to be separately
registered then what information about that network needs to
be entered into the RIPE Database?</div>
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<p>Denis, I believe that the first e-mail sent by you was inviting
the community to start a conversation. Furthermore, I believe that
NOW is the right time to have this discussion and clarify what is
required by policy (and maybe look at updating those policies as
well) and put it in writing in a new privacy policy.</p>
<p>While GDPR is already in effect, the RIPE Database contains
millions of contact details of private persons. Some ISPs
currently use the RIPE DB as their customer database and register
every single assignment they make to organisations or people. I
doubt any of the people used by the ISPs as admin-c or tech-c in
assignments actually know that their private data is made public
in the RIPE DB. Lastly, and this can be fixed easily if we all ask
for it, the RIPE NCC is creating every month hundreds of objects
that contain personal details with the registration of new LIRs.
The current state requires an update of policies and processes and
can not continue like this much longer.</p>
<p>I doubt that everyone that has a person object (containing
personal details - phone, e-mail, address, etc) in the RIPE
Database even knows about their personal data being public. I also
doubt that every person that registers a new LIR knows that their
personal details will be published in the RIPE Database and made
publicly available. There are several million person objects in
the RIPE Database that (I believe) should have been deleted once
GDPR kicked-in _or_ all of those persons should have been asked to
confirm that they accept to have their private information made
public in the RIPE Database.<br>
</p>
<p>To quote Peter Hessler "I am *not* happy for that data to be
published widely on the internet, so I have censored them on
purpose" - this is one way to hide personal details, many other
companies/people have chosen to censor or provide less than
accurate details.</p>
<p>Jan Ingvoldstad wants to see a better usable abuse contact
information. This is one of the details that we are asking for. We
are trying to make a list of contact information you all would
like to see registered in the RIPE Database for resource holders
and the questions in Denis' initial e-mail were supposed to start
and steer the conversation into finding exactly those details - to
then clarify and define where that information should be stored
(role object, org object, maintainer, etc)</p>
<p>Michiel Klaver had an interesting idea "Maybe make more use of
the 'role'-objects? Within organisations people come and go, while
their departments responsible for network operations and abuse
keep rolling. Listing a department as role and using a shared
e-mail address would reduce the ever increase of new
person-objects in the database." and I believe that the use of the
role objects should trump the use of the person object.</p>
<p>I personally believe that we should remove the person object from
the RIPE Database and use roles/organizations/maintainers/etc
instead. </p>
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<div>I will come straight to the point, which should be
controversial enough to start a discussion :) MY
interpretation of the wording in 6.2 is that the policy, as
written, requires an ORGANISATION object to be created for
these End Users if you register their network in the RIPE
Database.</div>
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<div>Let me explain my reasoning for this interpretation. The
policy refers to the End User as either an individual or an
organisation. In other words the End User is the '(legal)
entity' that operates the network. Just as the LIR is the
(legal) entity that holds the allocation resource. So when the
policy requires the contact details of the End User, it is
requiring the contact details of this operating entity. That
is not the "xxx-c" attributes in the INETNUM object, it is an
ORGANISATION object details.</div>
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<p>I believe that first we need to decide what kind of data must be
published in the RIPE Database and then decide in which objects to
store that data - be it an organisation object,
admin-c/tech-c/abuse-c, or a role object.</p>
<p>Once this is clear, we can amend current policies or propose a
privacy policy and reference it in the other policies.<br>
</p>
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<div>This takes us back to the long running discussion we had
with "abuse-c:" where many members refused to create separate
ORGANISATION objects for End Users just to add an "abuse-c:"
for them. But as it is currently written, this is exactly what
this policy requires. Perhaps the wording of this paragraph
6.2 doesn't reflect the original intent. So what we must now
do is look again at this situation and answer 3 basic
questions about these End Users:</div>
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<div>1/ What information do we need/want to store about the End
User?</div>
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<p>I'll bite and provide my answers:</p>
<p>- we should not store names of people - people come and go and
usually there is one person within a department that creates the
objects & requests the resources and then those objects are
inherited for many years. I believe that roles/department names
should be used. RIPE NCC has always recommended the use of role
objects for admin-c/tech-c/abuse-c. I am not sure when the RIPE
NCC changed their procedures and forms to include registration and
publication of personal data with the registration of every new
LIR but I believe they should revert and create role objects
instead.<br>
</p>
<p>- I think we should have an e-mail address and a phone number -
none of these should be personal details but the org's contact
details instead.</p>
<p>- physical address will come with a lot of questions: should this
be the legal or the mailing address of the org, of their tech
dept, of their outsourced tech dept in an other country, of their
lawyer/legal dept, etc...</p>
<p>- fax - who is still using fax, will you even think you will need
a fax sent to a holder of internet resources?</p>
<p>- what else is there? social media contacts? maybe links to
forms? how complicated do we want this to be?<br>
</p>
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<div>2/ What is the reason for storing this information?</div>
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<p>great question. The only reasons I can find are:</p>
<p>- someone is breaking my network (hijacks, ddos, peering issues,
etc) and I want to be able to swiftly contact them and ask them to
stop</p>
<p>- someone is sending abuse to my network/customers/contacts and I
want them to stop</p>
<p>- an LEA wants to be able to track the user of a resource swiftly
and, when they need to issue a subpoena, they need to know the
country where it should be sent and the right address</p>
<p>- the RIPE NCC already knows who is authorized to discuss
confidential information, the name should not be public though
unless the user really wants to and opts-in for his personal data
to be in the RIPE DB.</p>
<p>There may be other reasons as well, we'll have to wait for other
people to provide their feedback before we can collect it all and
do something with it (make a policy proposal).<br>
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<div>3/ Who needs this information?</div>
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I think I already answered this question by answering Q2... it would
be a network operator, someone receiving abuse, an LEA or the RIR.
In cases of (independent) assignments, it may be the LIR as well.<br>
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<div>If we can answer these basic questions then perhaps the
policy needs to be updated.</div>
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either update the IPv4/IPv6/ASN policies or propose a privacy policy
and reference it in the other policies as needed. I believe the
second option is better.<br>
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<div>cheers</div>
<div>denis</div>
<div><br>
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<div>co-chair DB-WG</div>
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<p>cheers,</p>
<p>elvis<br>
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<div> On Monday, 15 April 2019, 16:18:33 CEST, ripedenis---
via address-policy-wg <a class="moz-txt-link-rfc2396E" href="mailto:address-policy-wg@ripe.net"><address-policy-wg@ripe.net></a>
wrote: </div>
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<div>6.2 Network Infrastructure and End User
Networks</div>
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<div>When an End User has a network using public
address space this must be registered separately
with the contact details of the End User. Where
the End User is an individual rather than an
organisation, the contact information of the
service provider may be substituted for the End
Users.</div>
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