Due Diligence for the Quality of the RIPE NCC Registration Data

Introduction

The RIPE NCC has a mandate from the RIPE community to keep an up-to-date and correct Internet number resource registry. In order to comply with this mandate, the RIPE NCC performs due diligence on organisations the RIPE NCC registers Internet number resource for.

Due diligence refers to the controls the RIPE NCC performs:

• Before the registration of Internet number resources (see section 1)
• After the registration of Internet number resources (see section 2)

This document outlines the minimum information and documentation the RIPE NCC requires to make sure that the registration data is valid and up-to-date.

1. Before the registration of Internet number resources

The RIPE NCC registers Internet number resources to legal or natural persons that:

• Are contractually bound with either the RIPE NCC or a sponsoring LIR (see below section 1.1) and
• Meet the criteria defined by the RIPE Policies (see below section 1.2)

1.1. Establishment of an agreement

Legal or natural persons requesting the registration of Internet number resources and related services must have signed an agreement with either the RIPE NCC or a sponsoring LIR.

The RIPE NCC performs due diligence on these contractual agreements to verify that the contractual parties exist (and are valid) and that they are properly represented in the signing of the agreement.

For consistency purposes, all legal or natural persons that sign an agreement with the RIPE NCC are considered as intending to request Internet number resources.

Agreements signed with a sponsoring LIR must be submitted to the RIPE NCC. If there are doubts over the correctness of this information, the RIPE NCC reserves the right to contact the person that appears to have signed the agreement with the sponsoring LIR and to confirm the correctness of this information.

Each agreement signed with either the RIPE NCC or with a sponsoring LIR must be accompanied by supporting documentation proving the existence (and validity) of the legal or natural person (see below).

If the signing party is a natural person

If the signing party is a natural person, we have to be sure of their identity (before an agreement is concluded with them). Proof of identification could be:

• Valid identification documents (e.g., identification card, passport)
• Valid driving license with photo, birth certificate issued by the relevant municipality, notary declaration proving the existence of the person, etc. in the case of countries with non-official identification documents (e.g., the UK)

If the signing party is a legal person

If somebody is signing on behalf of a legal person, the RIPE NCC must verify that:

• The legal person is appropriately established by the local authorities or registered with the local authorities (see below under a. Proof of establishment/registration) and
• An authorised representative of the legal person approves this application (see below under b. Approval by authorised representative)

a. Proof of establishment/registration

Normally, proof of establishment of a legal person can be registration with the local authorities. When this is not available, another proof of establishment may be required (e.g., the law according to which the legal person was established).

The RIPE NCC reserves the right to check the validity of this documentation by requesting further documentation or additional information from third parties.

b. Approval by authorised representative

A contract with either the RIPE NCC or a sponsoring LIR must be signed by an authorised representative of the legal person.

In order to obtain a degree of certainty that the person that signs a contract is indeed authorised to represent the legal person, they must indicate:

- Their name

- Their position in the structure of the legal person

If there are doubts over the correctness of this information, the RIPE NCC will request proof of identity of the signing person.

1.2. Compliance with RIPE policies

The RIPE NCC performs due diligence on requests for Internet number resources and the validity of the distribution criteria before registration in order to ensure compliance with the appropriate RIPE Policies (IPv4 Address Allocation and Assignment Policies for the RIPE NCC Service Region, IPv6 Address Allocation and Assignment Policy, Autonomous System (AS) Number Assignment Policy).

During these checks, the RIPE NCC may ask for information about the network the Internet number resources are meant to be assigned to, as well as for documents supporting this information.

Details of this due diligence depend on the specific Internet number resources that are requested. These details can be found in the Request Forms and Supporting Notes and for IPv4 addresses in the IPv4 Registration Procedures.

2. After the registration or distribution of Internet number resources

After the agreement has been signed and the Internet number resources have been registered, the RIPE NCC must ensure that relevant registration data are maintained up-to-date and correct. To this end, the RIPE NCC performs audits (please see Audit activity) and has procedures to ensure that (legal or natural) persons that have registered Internet number resources are aware of the changes that must be communicated to the RIPE NCC (e.g.,see RIPE NCC procedural documents about transfers of Internet number resource records and change of a Member's official name, Independent resources – contractual changes between sponsoring LIR and End User and Closure of LIR and Deregistration of Internet Number Resources.

Submission of a change

Changes in the registration data must be requested by:

- A registered contact person (somebody that has been delegated the authority to contact the RIPE NCC on behalf of the person that has been registered Internet number resources through the LIR portal); or

- An authorised person (somebody that has the general authority to act on behalf of the person that has been registered Internet number resources).

If there is any doubt about the identity or the authority of the person requesting these changes, the RIPE NCC reserves the right to request additional documentation (e.g., proof of identity, court decisions, etc.) and to request support or information from third parties.

The RIPE NCC will ask the requester to submit all relevant documentation that supports this change. Such documentation may include:

• Registration papers from local authorities of the country the organisation is registered in
• Court decisions establishing, recognising or ordering the change
• Agreements mentioning the change
• Confirmation signed by an authorised person

For more information, please see the procedural document about transfers of Internet number resource records and change of a Member's official name .

The RIPE NCC reserves the right to check the validity of this documentation by requesting support or information from third parties.

3. Confidentiality and privacy issues

The RIPE NCC maintains a duty of confidentiality towards the legal or natural persons that request Internet number resources. Information passed to the RIPE NCC is securely stored and will not be distributed further than is necessary, within the RIPE NCC and beyond.

Details of the process of handling personal data by the RIPE NCC can be found in the RIPE NCC Privacy Statement.