On Sun, Oct 09, 2022 at 01:33:43PM +0200, Sander Steffann via db-wg wrote:
The RIPE NCC has prepared an impact analysis on this latest proposal version to
support the community???s discussion.
You can find the proposal and impact analysis at:
https://www.ripe.net/participate/policies/proposals/2022-01
https://www.ripe.net/participate/policies/proposals/2022-01#impact-analysis
The executive board feedback corresponds to my opinion on this policy,
especially these points:
- It significantly reduces the usability for one of its core purpose - being
able to contact resource holders about their number resources.
This presumes a "traditional" model of resource assignment and
allocation that is no longer ubiquitous. For virtually all LIRs I
have a hand in managing resources for, the end users have neither
the inclination nor the ability to manage the /29 they are
assigned - they expect their provider to do this.
Should an end-user wish to manage their assignment themselves, or
the LIR to devolve this responsibility, they can still create an
inet(6)num for the assignment.
In the NCC's Impact Analysis, it states as the legal reasoning
for GDPR purposes "the legitimate interest of the RIPE
community". I consider this reasoning naive. The "RIPE
community is an unconstituted and ephemeral collection of
individuals and can't be a legal subject. Whom do I take to court
if I want to test my privacy rights against the "interest of the
RIPE community"? Every member of the mailing lists individually?
- We would welcome a discussion that focuses more on which parts of the data
are publicly available, rather than a sweeping removal.
Any data that should not be publically available should also not be
in this database. A reasoned argument may be made to have this
data in a *separate*, non-public database.
That said, I still oppose this proposal based on other grounds,
such as the attempt to introduce yet another "verification"
requirement and the resulting overhead to both the NCC and the
membership.
rgds,
Sascha Luck
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