[anti-abuse-wg] 2013-01 Discussion Period extended until 26 June 2013 (Openness about Policy Violations)

All,

please find below comments on 2013-01 v2.0. I refer to:
https://www.ripe.net/ripe/policies/proposals/2013-01

> 1. Transparency on reported policy violations

>The RIPE NCC accepts reports about Internet number resource
>registrations such as violation of RIPE Policies and RIPE NCC
>Procedures, provision of untruthful information to the RIPE NCC,
>bankruptcy, liquidation or insolvency of resource holders and incorrect
>contact information in the RIPE Database.

>The RIPE NCC will handle all such reports and publish statistics about
>such reports publicly.

>The RIPE NCC will publish regularly statistics of the reports that have
>been received but not yet closed. These statistics will show the number
>of reports in each of the following categories:

>    'new': Submitted but not being investigated yet      
>    'under-investigation': The RIPE NCC is investigating the report 

>In addition to these running totals the RIPE NCC publishes statistics
>about how these reports have been closed. These statistics are divided
>into the following categories:   
     
>    'closed, out-of-scope': The report is out of scope for the RIPE NCC
>reporting system        
>    'closed, resolved-by-holder': The resource holder has resolved any
>problems   
>    'closed, resources-returned': The report has led to resources being
>returned to the RIPE NCC  
>    'closed, no-violation': After investigation the RIPE NCC could not
>find any violation of policy 


The text needs to state explicitly that this reporting is anonymised, ie
does not contain any information that can be used to identify either the
resource or the holder.


>2. Progress

>The RIPE NCC will provide a way to follow the progress of the
>investigation for both the person submitting a report and the
>organization(s) mentioned in the report.

>This information will not be published publicly.

This is better than v1.0 but still leaves room for abuse, viz. there is
no mechanism to ensure the information provided by the NCC is not
published by the submitter.  A possible solution would be to restrict
submission of complaints to the LIRportal , thereby ensuring that the
submitter is contractually obliged to the NCC and disclosure of this
information can be appropriately sanctioned. Such sanctions would need
to be enough to discourage abuse.

>3. Transparency on reclaimed resources

>As the 'delegated' files show the resources that the RIPE NCC has
>delegated to others, so will the 'returned' files show the resources
>delegated or returned to the RIPE NCC.  The format of the 'returned'
>files will be publicly published to facilitate automatic processing.

>The reason for resources being returned can be:

>    'returned': Returned by the holder
>    'contact-lost': The RIPE NCC could not contact the holder
>    'policy-violation': Reclaimed because of a policy violation

I'd like to know more about the use-case for this, particularly under
the aspect of "automated processing"

On balance, this is better than the first attempt, however I still think
that the rights of members are insufficiently safeguarded. Thus I remain
opposed to this version too.

Kind Regards,
Sascha Luck