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Today's Topics:
1. @EXT: 2018-05 New Policy Proposal (Publication of Legal
Address of Internet Number Resource Holder) - updating the
proposal? (Marcolla, Sara Veronica)
2. Re: @EXT: 2018-05 New Policy Proposal (Publication of Legal
Address of Internet Number Resource Holder) - updating the
proposal? (Randy Bush)
3. Re: @EXT: 2018-05 New Policy Proposal (Publication of Legal
Address of Internet Number Resource Holder) - updating the
proposal? (Carlos Fria?as)
4. @EXT: RE: 2018-05 New Policy Proposal (Publication of Legal
Address of Internet Number Resource Holder) - updating the
proposal? (Marcolla, Sara Veronica)
5. Re: @EXT: 2018-05 New Policy Proposal (Publication of Legal
Address of Internet Number Resource Holder) - updating the
proposal? (Nik Soggia)
----------------------------------------------------------------------
Message: 1
Date: Mon, 8 Oct 2018 15:46:47 +0000
From: "Marcolla, Sara Veronica" <[email protected]>
To: "'[email protected]'" <[email protected]>
Subject: [ncc-services-wg] @EXT: 2018-05 New Policy Proposal
(Publication of Legal Address of Internet Number Resource Holder) -
updating the proposal?
Message-ID:
<[email protected]>
Content-Type: text/plain; charset="us-ascii"
Hi everyone,
All the comments exchanged in the list made me thinking a lot about the wording
of this proposal. I have noticed that the lively discussion around the policy
is bringing a lot of attention on the dichotomy between the individual (which I
agree completely, should be protected in their fundamental rights, with
provisions such as the GDPR and others), and the company/corporation. It seems
to me so far that many of us would indeed support the idea of having the legal
address published of companies, but having concerns about personal data. The
aim of this proposal is indeed to focus on companies, not individuals, and even
the smallest company has to be registered as such (if not for other reasons,
for tax reasons). Individuals will be anyways protected by a hierarchically
higher set of rules: the fundamental rights, such as those championed by GDPR
for example.
At this point I am asking whether you support a proposal, the clarifies that
only the legal address of companies will be published, and that states clearly
that individuals information will be protected? After all, the reasoning here
is that if a resource holder is registered with a national company registry,
they have a legal address which can be published. This legal address is usually
publicly available anyhow and can be then validated by the RIPE NCC.
Looking forward to hear the feedback to this idea for an amendment to the
proposal.
Sara
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------------------------------
Message: 2
Date: Mon, 08 Oct 2018 09:30:39 -0700
From: Randy Bush <[email protected]>
To: "Marcolla, Sara Veronica" <[email protected]>
Cc: "'[email protected]'" <[email protected]>
Subject: Re: [ncc-services-wg] @EXT: 2018-05 New Policy Proposal
(Publication of Legal Address of Internet Number Resource Holder) -
updating the proposal?
Message-ID: <[email protected]>
Content-Type: text/plain; charset=US-ASCII
At this point I am asking whether you support a proposal, the
clarifies that only the legal address of companies will be published
not particularly
the contract is between the ncc and the registrant; not the community
and the registrant.
whois (not the irr, which is confuddled with it in the ripe registry)
is useless and should die.
randy
------------------------------
Message: 3
Date: Mon, 8 Oct 2018 22:50:25 +0100 (WEST)
From: Carlos Fria?as <[email protected]>
To: "Marcolla, Sara Veronica" <[email protected]>
Cc: "'[email protected]'" <[email protected]>
Subject: Re: [ncc-services-wg] @EXT: 2018-05 New Policy Proposal
(Publication of Legal Address of Internet Number Resource Holder) -
updating the proposal?
Message-ID:
<[email protected]>
Content-Type: text/plain; charset=US-ASCII; format=flowed
On Mon, 8 Oct 2018, Marcolla, Sara Veronica wrote:
Hi everyone,
Greetings,
All the comments exchanged in the list made me thinking a lot about the
wording of this proposal. I have noticed that the lively discussion
around the policy is bringing a lot of attention on the dichotomy
between the individual (which I agree completely, should be protected
in their fundamental rights, with provisions such as the GDPR and
others), and the company/corporation. It seems to me so far that many of
us would indeed support the idea of having the legal address published
of companies, but having concerns about personal data. The aim of this
proposal is indeed to focus on companies, not individuals, and even the
smallest company has to be registered as such (if not for other reasons,
for tax reasons). Individuals will be anyways protected by a
hierarchically higher set of rules: the fundamental rights, such as
those championed by GDPR for example.
Well, LIR addresses are already published on the RIPE NCC's website.
LIR's customers addresses may not be part of whois.ripe.net... well...
i know some LIRs tend to protect their customers identity, to prevent
competitors to approach them with better contractual conditions (this is
not the case of the LIR i work for, which is a NREN)
At this point I am asking whether you support a proposal, the clarifies
that only the legal address of companies will be published, and that
states clearly that individuals information will be protected? After
all, the reasoning here is that if a resource holder is registered with
a national company registry, they have a legal address which can be
published. This legal address is usually publicly available anyhow and
can be then validated by the RIPE NCC.
I see added value in "validation by the RIPE NCC", despite the natural
cost this will bring...
However, i wonder what should be the procedure if RIPE NCC finds that
company X registers a new company Y in a different country/economy
resorting to a "virtual office" address.
Looking forward to hear the feedback to this idea for an amendment to the
proposal.
Good luck!
Best Regards,
Carlos
Sara
*******************
DISCLAIMER : This message is sent in confidence and is only intended for the
named recipient. If you receive this message by mistake, you may not use, copy,
distribute or forward this message, or any part of its contents or rely upon
the information contained in it.
Please notify the sender immediately by e-mail and delete the relevant e-mails
from any computer. This message does not constitute a commitment by Europol
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------------------------------
Message: 4
Date: Tue, 9 Oct 2018 07:41:15 +0000
From: "Marcolla, Sara Veronica" <[email protected]>
To: 'Carlos Fria?as' <[email protected]>, "'[email protected]'"
<[email protected]>
Subject: [ncc-services-wg] @EXT: RE: 2018-05 New Policy Proposal
(Publication of Legal Address of Internet Number Resource Holder) -
updating the proposal?
Message-ID:
<[email protected]>
Content-Type: text/plain; charset="iso-8859-1"
Hi Carlos,
I understand the logic behind the protection of LIRs for competition reasons -
however I am positively sure that this right cannot be considered anywhere
close to the right to privacy and protection of individuals.
Regarding your comment on the company change, I believe that the case of change
of holdership should firstly have to pass the existing RIPE NCC due diligence
checks for transfers/mergers. It would then still be useful to actually have
the legal address of this new company, as it helps to identify the company who
is the registered resource holder.
Sara
-----Original Message-----
From: Carlos Fria?as [mailto:[email protected]]
Sent: 08 October 2018 23:50
To: Marcolla, Sara Veronica
Cc: '[email protected]'
Subject: Re: [ncc-services-wg] @EXT: 2018-05 New Policy Proposal (Publication
of Legal Address of Internet Number Resource Holder) - updating the proposal?
On Mon, 8 Oct 2018, Marcolla, Sara Veronica wrote:
Hi everyone,
Greetings,
All the comments exchanged in the list made me thinking a lot about the
wording of this proposal. I have noticed that the lively discussion
around the policy is bringing a lot of attention on the dichotomy
between the individual (which I agree completely, should be protected
in their fundamental rights, with provisions such as the GDPR and
others), and the company/corporation. It seems to me so far that many of
us would indeed support the idea of having the legal address published
of companies, but having concerns about personal data. The aim of this
proposal is indeed to focus on companies, not individuals, and even the
smallest company has to be registered as such (if not for other reasons,
for tax reasons). Individuals will be anyways protected by a
hierarchically higher set of rules: the fundamental rights, such as
those championed by GDPR for example.
Well, LIR addresses are already published on the RIPE NCC's website.
LIR's customers addresses may not be part of whois.ripe.net... well...
i know some LIRs tend to protect their customers identity, to prevent
competitors to approach them with better contractual conditions (this is
not the case of the LIR i work for, which is a NREN)
At this point I am asking whether you support a proposal, the clarifies
that only the legal address of companies will be published, and that
states clearly that individuals information will be protected? After
all, the reasoning here is that if a resource holder is registered with
a national company registry, they have a legal address which can be
published. This legal address is usually publicly available anyhow and
can be then validated by the RIPE NCC.
I see added value in "validation by the RIPE NCC", despite the natural
cost this will bring...
However, i wonder what should be the procedure if RIPE NCC finds that
company X registers a new company Y in a different country/economy
resorting to a "virtual office" address.
Looking forward to hear the feedback to this idea for an amendment to the
proposal.
Good luck!
Best Regards,
Carlos
Sara
*******************
DISCLAIMER : This message is sent in confidence and is only intended for the
named recipient. If you receive this message by mistake, you may not use, copy,
distribute or forward this message, or any part of its contents or rely upon
the information contained in it.
Please notify the sender immediately by e-mail and delete the relevant e-mails
from any computer. This message does not constitute a commitment by Europol
unless otherwise indicated.
*******************
*******************
DISCLAIMER : This message is sent in confidence and is only intended for the
named recipient. If you receive this message by mistake, you may not use, copy,
distribute or forward this message, or any part of its contents or rely upon
the information contained in it.
Please notify the sender immediately by e-mail and delete the relevant e-mails
from any computer. This message does not constitute a commitment by Europol
unless otherwise indicated.
*******************
------------------------------
Message: 5
Date: Tue, 9 Oct 2018 10:13:48 +0200
From: Nik Soggia <[email protected]>
To: "'[email protected]'" <[email protected]>
Subject: Re: [ncc-services-wg] @EXT: 2018-05 New Policy Proposal
(Publication of Legal Address of Internet Number Resource Holder) -
updating the proposal?
Message-ID: <[email protected]>
Content-Type: text/plain; charset=iso-8859-15; format=flowed
Il 08/10/18 17:46, Marcolla, Sara Veronica ha scritto:
After all, the reasoning here is that if a resource holder is registered with a
national company registry, they have a legal address which can be published.
Maybe the key to make everyone happy is the word "can" instead of
"must". Why not make it optional?
If companies are in good faith or they like the idea then they will use
it, and they will also be happy to maintain the data.
Otherwise it will be just a waste of time on another
wrong/outdated/malicious dataset.
How fun it is to check the validity of a validated address?
Life is too short, right?
This legal address is usually publicly available anyhow and can be then
validated by the RIPE NCC.
Duplicating data instead of referencing it breaks the first database
design rule.
Companies are forced by law to keep their chamber of commerce data up to
date. THAT is the best source of information and it is readily
available. Don't reinvent the wheel.
This proposal is can of worms:
- same data in many places is difficult to maintain and prone to errors
- doesn't stop bad actors
- quickly provides massive information to data harvesters and scammers
In my opinion this proposal is not the right way to identify a resource
holder the way you dreamt.
It's not a elegant solution and in general I have a bad feeling about
it, imagine a blunt tool that not only will make a poor job but also
will bring a lot of frustration.
Ok for me if it is optional, otherwise I'm against.
Regards,
