Hi Nick I am preparing a reply to your comments. I need to do some research to give you a full response. This week I'm in a rural French village with virtually no Internet connectivity. So a quick response is unlikely.
cheers denis Proposal author On Sun, 19 Jun 2022, 16:06 Nick Hilliard, <[email protected]> wrote: > denis walker via db-wg wrote on 16/06/2022 16:05: > > I have listened to your comments in recent discussions and had some > > preliminary talks with the RIPE NCC about what could be implemented. So > > now we have a second version of my proposal on personal data. > > There are some fairly serious structural issues with the justification > in this proposal, for example: > > - that there's something new with GDPR that wasn't there before > - that the RIPE database is not GDPR compliant > - repeated claims that "In almost all cases, personal data is not needed". > - etc > > GDPR, and previously the 1995 Data Protection Directive, has been > addressed continuously by the RIPE NCC over the years. There are some > blog posts on the RIPE NCC web site which provide an overview of the > current lawful basis for holding and publishing the information: > > > > https://www.ripe.net/about-us/legal/corporate-governance/gdpr-and-the-ripe-ncc > > So in the absence of firm reasoning to the contrary, this policy needs > to step back quite far from claiming or hinting at GDPR non-compliance. > > There are numerous other cases where the current justification presents > opinions without providing an adequate factual basis. > > Incidentally, I'm not arguing that there shouldn't be changes to the > scope and style of information contained in the ripe database, but as it > stands, the scope of this policy proposal isn't justified by the > rationale provided. > > Nick >
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