Hi Denis,
The proposed amendments have to be first presented to the Executive Board.
As per the 'Adoption Process for RIPE NCC Corporate Documents
<https://www.ripe.net/about-us/legal/corporate-governance/adoption-process-for-ripe-ncc-corporate-documents>',
if the Executive Board decides that feedback from the membership or RIPE
community is required, the document will be published as a draft and
will be shared with the members or the RIPE community via the
appropriate mailing lists.
Maria
On 26/07/2023 15:15, denis walker wrote:
Hi Maria
Thanks for this. Just to remind everyone, can you publish the final
proposed amendments that you are going to put to the board.
cheers
denis
co-chair DB-WG
On Wed, 26 Jul 2023 at 11:54, Maria Stafyla<[email protected]> wrote:
Hi Denis,
This is still in progress.
Our intention is to submit the proposed amendments to the RIPE Database
Terms
and Conditions for the Executive Board's review and approval at their
next meeting, which
is going to take place in October 2023.
Kind regards,
Maria
On 19/07/2023 19:54, denis walker wrote:
Hi Maria
"> On the implementation side, we will discuss internally how we can
make it explicit when adding a geofeed attribute that the privacy of
the users of the related resources is respected."
How are these internal discussions progressing? Do you have any suggestions yet?
">We will work on updating the RIPE Database Terms and Conditions in
order to specify this. In line with the Adoption Process for RIPE NCC
Corporate Documents, the proposed amendments will have to be approved
by the RIPE NCC Executive Board."
Has the Exec Board considered this yet?
cheers
denis
co-chair DB-WG
On Fri, 19 May 2023 at 16:27, Maria Stafyla<[email protected]> wrote:
Hi Denis, all,
To recap the discussion on this topic: after it was first suggested to
introduce geofeed as a new attribute in the RIPE Database, we raised some legal
concerns related to its implementation and suggested that technical
restrictions are required to minimise the associated legal risks. The main
concerns arose because providing geolocation information, including geolocation
information that might contain personal data, is not covered under the current
purposes of the RIPE Database.
From the discussion on the RIPE Database Working Group mailing list prior to
RIPE 85, various feedback was provided on the use of geolocation information
and the reasons for which this is useful for network and content operators. At
the RIPE 85 Database Working Group session, the Working Group chairs declared
there was consensus that geolocation is a purpose the RIPE Database has to
fulfil. They also asked for input on the process to follow for amending the
current RIPE Database Terms and Conditions and working on a draft purpose. A
draft purpose has now been suggested, along with the question of whether this
addresses all legal concerns and if we can go ahead with the implementation of
the geofeed attribute.
Having established that geolocation is a purpose and looking at the proposed
text, our advice is to make this more explicit and explain why personal data
may be processed for the purpose of geolocation. We will work on updating the
RIPE Database Terms and Conditions in order to specify this. In line with the
Adoption Process for RIPE NCC Corporate Documents, the proposed amendments will
have to be approved by the RIPE NCC Executive Board.
On the implementation side, we will discuss internally how we can make it
explicit when adding a geofeed attribute that the privacy of the users of the
related resources is respected. This is necessary because, as mentioned in our
previous replies, although the RIPE NCC is not the party inserting the data in
the csv file, legally we are co-responsible for the information inserted in the
RIPE Database (even if it is not hosted there directly). As with all the other
personal data in the RIPE Database, the party that enters it has the
responsibility to inform the individual to whom the data pertains and to obtain
their explicit consent before entering it (Art. 6.3 RIPE Database Terms and
Conditions).
Kind regards,
Maria Stafyla
Senior Legal Counsel
RIPE NCC
On 25/04/2023 11:25, Maria Stafyla wrote:
Hi Denis, all
This is to confirm that we are already working on our analysis and we will get
back to you as soon as possible.
Kind regards,
Maria Stafyla
Senior Legal Counsel
RIPE NCC
On 13/04/2023 12:29, denis walker wrote:
Colleagues
A question for the legal team at the RIPE NCC. Would a simple purpose,
as suggested below, address all the concerns you had about the use of
the "geofeed:" attribute and allow you to remove any restrictions you
felt were necessary when it was introduced?
cheers
denis
co-chair DB-WG
---------- Forwarded message ---------
From: denis walker<[email protected]>
Date: Tue, 11 Apr 2023 at 10:41
Subject: Geofeed purpose
To: Database WG<[email protected]>
Colleagues
The conversation on deploying geofeed died shortly after RIPE 85. The
last comment was from myself asking if anyone was willing to propose
some wording for a new purpose covering the use of the RIPE Database
for geolocation information. No one proposed any wording. So below I
have made a proposal for a new purpose. Your comments are appreciated.
cheers
denis
co-chair DB-WG
The RIPE Database contains information for the following purposes:
Ensuring the uniqueness of Internet number resource usage through
registration of information related to the resources and Registrants
Publishing routing policies by network operators (IRR)
Facilitating coordination between network operators (network
problem resolution, outage notification etc.)
Provisioning of Reverse Domain Name System (DNS) and ENUM delegations
Providing information about the Registrant and Maintainer of
Internet number resources when the resources are suspected of being
used for unlawful activities, to parties who are authorised under the
law to receive such information.
Scientific research into network operations and topology
Providing information to parties involved in disputes over
Internet number resource registrations to parties who are authorised
under the law to receive such information.
Providing information about the geolocation usage of Internet number resources.
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