[anti-abuse-wg] RIPE Database Proxy Service Issues

[Apologies for duplicate emails]

Dear colleagues,

There has been discussion on various mailing lists regarding the status 
of the RIPE Database Proxy Service.

Before I address the issues that arose, I'd like to give you some 
background information on the service itself that may help with the 
discussions.

Technical Background
--------------------
To prevent the automatic harvesting of personal information (real names, 
email addresses, phone numbers) from the RIPE Database, there are PERSON 
and ROLE object query limits defined in the RIPE Database Acceptable Use 
Policy. This is set at 1,000 PERSON or ROLE objects per IP address per 
day. Queries that result in more than 1,000 objects with personal data 
being returned result in that IP address being blocked from carrying out 
queries for that day.

Users of the RIPE Database have unlimited access to Network Information 
Centre (NIC)-related objects. They can use the -r flag in order to 
filter out personal objects and query NIC objects without any limitations.

The RIPE Database Proxy Service allows websites to provide a third party 
interface to the RIPE Database. Without the proxy service, the third 
parties would quickly run into the limits set on RIPE Database queries. 
With the proxy service, we whitelist the third party IP address and ask 
them to pass their user's IP address to us, so limits are only set on 
the user's IP address, not the third party's.

There is no technical way to ensure that the user IP addresses passed to 
us by the third party are valid. Potentially, third party users of the 
proxy service could harvest all personal data in the RIPE Database 
(approximately 2 million objects) in a matter of hours. To ensure that 
the RIPE NCC's Terms and Conditions are followed, we require a contract 
between the third party and the RIPE NCC.

Users of the Proxy Service
--------------------------
In the past ten years, the RIPE NCC has had 31 requests for the proxy 
service and over the past year, there have been only four active users 
of the service. Of these four, one is already a RIPE NCC member.

NIC Information
---------------
All NIC information is still available without access to the proxy 
service. In the normal presentation of whois data, there is a redirect 
system that allows users with a normal whois client to deal directly 
with the RIPE Database whois service. There is no need for a proxy 
service in this scenario. The proxy service is only necessary if the 
data needs to be presented in alternative forms, such as on a third 
party's website.

The limits imposed on RIPE Database queries only apply to personal data. 
Users can always access NIC data in any form they like if they are happy 
not to receive personal data.

On 6 March 2012, the RIPE NCC proposed to change the default behaviour 
of the query system to instead return only "ALLOWED" results if a user 
had reached their daily personal data query limit, but there was 
disagreement over this on the mailing list so the change was not 
implemented. The proposal is available at:
http://www.ripe.net/ripe/mail/archives/db-wg/2012-March/003885.html

Legal Considerations
--------------------
The RIPE NCC operates under European Data Protection laws, so to avoid 
risk in this area we insist on having a contract with third parties who 
wish to use the proxy service.

The RIPE NCC and its Executive Board believes that the proxy service 
should become a member service because it tightens the contractual 
relationship between the RIPE NCC and third parties. Currently, no such 
agreement that meets the EU Data Protection legislation is in place 
between the RIPE NCC and the proxy service users.

In order to tighten the contractual relationship between the RIPE NCC 
and the Proxy service users, taking into account the recent approval of 
the Charging Scheme 2013 that caused a simplification of the contractual 
agreements between the RIPE NCC and its service users, the RIPE NCC 
offered to conclude the membership agreement for continuation of the 
service.

Next Steps?
------------
The Executive Board approved changes to the draft version of the 
Activity Plan and Budget 2013, and the RIPE NCC published the final 
version on 13 December 2012:
http://www.ripe.net/internet-coordination/news/announcements/ripe-ncc-activity-plan-and-budget-2013

We do apologise, however, that the changes regarding the proxy service 
were not more explicitly communicated to the members and the RIPE 
community in advance of the final publication of the Activity Plan.

The RIPE NCC asks that non-RIPE NCC member proxy service users become 
members but we propose to waive their membership fee until the 
discussion of the RIPE NCC Charging Scheme 2014 takes place. This will 
give the membership and community the opportunity to discuss the best 
way forward for the proxy service in the coming months while ensuring a 
strong contractual bond between the RIPE NCC and users of this service.

In the meantime, there will be no changes to the proxy service and no 
loss of functionality for the community.

The RIPE NCC and its Executive Board will return to its members with 
proposals for ways to ensure that their wishes are met with regard to 
service developments while allowing the RIPE NCC to be operate 
efficiently and responsively.

If you have any comments on this issue, please direct them to the RIPE 
NCC Services Working Group mailing list <ncc-services-wg at ripe.net>.

Best regards,

Axel Pawlik
Managing Director
RIPE NCC