On Mon, Jul 17, 2017 at 01:04:26AM -0400, hostmas...@uneedus.com wrote:
> John,
> 
> I think this is the FCC ruling he speaks of, and it does seem to shut down 
> public disclosures of most of what is contained in SWIP/WHOIS without 
> customer consent.  This has been the rule for regular phone calls for a 
> long time, called CPNI. Until today I did not realise the FCC extended 
> this to the internet. 

I'm not currently providing this service, but I did so when the 
discussion came around and recall when this was extended. It was 
specifically regarding services. All the CPNI rules stremmed from 
a customer's existing providers having an unfair marketing advantage 
by looking at the customer's services and usage. It was rooted in 
the age of slamming and "pretexting".  Even expanding that to generic 
Internet service did not change the definition to remove the scope 
of services provided to a customer.

[snip]
> http://hraunfoss.fcc.gov/edocs_public/attachmatch/FCC-07-22A1.pdf
[snip]

In that doc, see "Discussion" section F "Extension of CPNI 
Requirements to Providers of Interconnected VoIP Service". Even 
with ISPs under title 2, without inclusion of service information 
a public registry has [IME] no relationship to the CPNI issue. 
That said, my personal suggestion would be to not include type of 
service ( -DSL-, -FTTH-, etc) in the SWIP netblock name or 
elsewhere in the record purely from an infosec PoV. :-)

Cheers (this is not legal advice),

Joe

-- 
Posted from my personal account - see X-Disclaimer header.
Joe Provo / Gweep / Earthling 
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