[anti-abuse-wg] [db-wg] RIPE NCC's proposed implementation of Abuse Contact Management in the RIPE Database

Dear Florien

Thank you for your comments. You have touched on several issues here. 
Lets take them individually.

Currently all data in the RIPE Database is publicly available, except 
password hashes. So any individual object can be queried and the full 
data returned. The RIPE Database does contain personal data and this 
data is also publicly available by querying the database, but with 
limits. To avoid data mining of this personal data, which is not 
required for any of the purposes of the database, the RIPE NCC does not 
allow bulk access to the personal data. The data examples you refer to 
are from the daily dump of the database. These have been "dummified" to 
remove personal data and references to personal data.

The dummy PERSON and ORGANISATION objects you listed are place holders 
in the data dumps to maintain a consistent data set. The real objects 
and references are available if you query the RIPE Database within the 
acceptable use limits. None of the data that the LIRs maintain is 
hidden. But that part that is considered personal has some limits.

The discussions around the abuse handling in the Anti Abuse Working 
Group have made it clear that this will not be personal data. So these 
ROLE objects will be available without the limits that personal data is 
subject to. They will also be available in the bulk data dumps. This is 
why we propose to allow an "abuse-c:" attribute to reference only a ROLE 
object and not a PERSON object. As Kaveh said, the ROLE object was not 
designed to, and should not, hold personal data. The tools the RIPE NCC 
will provide to facilitate abuse contact data entry will make it very 
clear that it will be available without limits and should not contain 
any personal data. The RIPE Database query service will also provision 
easy access to the abuse contact data related to individual resources 
without the need for users to drill down through individual data objects 
or hit any access limits. This should also help to avoid misuse of the 
personal data held in the RIPE Database.

Regards,
Denis Walker
Business Analyst
RIPE NCC Database Group


On 16/11/2012 07:06, Florian Weimer wrote:
> * Kaveh Ranjbar:
>
>> One of the reasons that it is only tied to the "role" object and not
>> the "person" object is to avoid those issues. A role object is not
>> designed to hold personal information, it is a representation of a
>> unit in an organisation. The "abuse-mailbox:" attribute is also
>> supposed to represent the generic email address of the contact point
>> for the abuse handling entity within an organisation, not a real
>> person. We will place clarifying notifications about this when users
>> enter the data.
>>
>> None of the objects in the chain, "inetnum/inet6num/aut-num",
>> "organisation" and "role" are provisioned as, or designed to be
>> private data holders.
>
> Are you sure?  After all, you anonymize these objects in the database
> dumps, citing data protection concerns:
>
> aut-num:         AS3255
> as-name:         UARNET-AS
> descr:           State Enterprise Scientific and Telecommunication Centre "Ukrainian Academic and Research Network" of the Institute for Condensed Matter Physics of the National Academy of Sc
> ience of Ukraine (UARNet)
> descr:           EARN-Ukraine
> [...]
> admin-c:         DUMY-RIPE
> tech-c:          DUMY-RIPE
> [...]
> changed:         [...]
> source:          RIPE
> remarks:         ****************************
> remarks:         * THIS OBJECT IS MODIFIED
> remarks:         * Please note that all data that is generally regarded as personal
> remarks:         * data has been removed from this object.
> remarks:         * To view the original object, please query the RIPE Database at:
> remarks:         * http://www.ripe.net/whois
> remarks:         ****************************
>
> inet6num:        2001:0658:021A::/48
> netname:         DE-TRMD-HACKETHAL-1
> descr:           IPv6 Markus Hackethal
> descr:           Langenfeld
> country:         DE
> admin-c:         DUMY-RIPE
> tech-c:          DUMY-RIPE
> status:          ASSIGNED
> mnt-by:          TRMD-MNT
> changed:         [...]
> source:          RIPE
> remarks:         ****************************
> remarks:         * THIS OBJECT IS MODIFIED
> remarks:         * Please note that all data that is generally regarded as personal
> remarks:         * data has been removed from this object.
> remarks:         * To view the original object, please query the RIPE Database at:
> remarks:         * http://www.ripe.net/whois
> remarks:         ****************************
>
> inetnum:         80.16.151.184 - 80.16.151.191
> netname:         NETECONOMY-MG41731
> descr:           TELECOM ITALIA LAB SPA
> country:         IT
> admin-c:         DUMY-RIPE
> tech-c:          DUMY-RIPE
> status:          ASSIGNED PA
> [...]
> changed:         [...]
> source:          RIPE
> remarks:         ****************************
> remarks:         * THIS OBJECT IS MODIFIED
> remarks:         * Please note that all data that is generally regarded as personal
> remarks:         * data has been removed from this object.
> remarks:         * To view the original object, please query the RIPE Database at:
> remarks:         * http://www.ripe.net/whois
> remarks:         ****************************
>
> organisation:    ORG-NCC1-RIPE
> org-name:        Dummy organisation name for ORG-NCC1-RIPE
> org-type:        RIR
> address:         Dummy address for ORG-NCC1-RIPE
> e-mail:          unread at ripe.net
> mnt-ref:         RIPE-NCC-RIS-MNT
> mnt-ref:         RIPE-NCC-HM-MNT
> mnt-by:          RIPE-NCC-HM-MNT
> changed:         unread at ripe.net 20000101
> source:          RIPE
> remarks:         ****************************
> remarks:         * THIS OBJECT IS MODIFIED
> remarks:         * Please note that all data that is generally regarded as personal
> remarks:         * data has been removed from this object.
> remarks:         * To view the original object, please query the RIPE Database at:
> remarks:         * http://www.ripe.net/whois
> remarks:         ****************************
>
> person:         Placeholder Person Object
> address:        RIPE Network Coordination Centre
> address:        P.O. Box 10096
> address:        1001 EB Amsterdam
> address:        The Netherlands
> phone:          +31 20 535 4444
> nic-hdl:        DUMY-RIPE
> mnt-by:         RIPE-DBM-MNT
> remarks:        **********************************************************
> remarks:        * This is a placeholder object to protect personal data.
> remarks:        * To view the original object, please query the RIPE
> remarks:        * Database at:
> remarks:        * http://www.ripe.net/whois
> remarks:        **********************************************************
> changed:        ripe-dbm at ripe.net 20090724
> source:         RIPE
>
> The latter is from the ripe.db.role.gz file.  (Curiously, the
> "changed:" lines are left intact in the dump.)
>
> I worry that most LIRs put quite a bit of effort into updating the
> contact information, and then RIPE NCC decides to hide it because it's
> considered personal data, like all the other contact information
> currently in the database.
>
>