[db-wg] Removing personal data from bulk output from the RIPE Database

Denis,

> We?ve received feedback from different users and researchers that we are
> overdoing the dummification. For example, one can obtain all references
> to personal objects without hitting any personal object result limits by
> querying the live RIPE Database with proper flags (like -r). This makes
> the "dummification" of these references in the data dumps meaningless.

I do not buy this argument.  We know that certain access restrictions
can be circumvented eventually by renting the ultimate botnet and do a mass
harvest.  That doesn't render restrictions useless.
One could argue that if certain access controls were implemented to achieve
a certain goal and other methods open a path around these controls, those other
methods (the -r flag in this case) ought to be reviewed instead.

> In order to improve the usability of the data dumps and streams, we are
> proposing to change the "dummification" algorithm to keep the actual
> personal objects and all references to them and only obfuscate the
> fields with personal data (for example real names, phone numbers and
> addresses). The new algorithm will also try to preserve data that is
> useful for researchers, while not revealing any data that might expose
> the identity of the date subject. For example, we are proposing to keep
> the first half of phone number digits or to keep the domain part of
> email addresses.

I am missing a list of data protection goals that were desired to be met
by the original implementation and a serious assessment why they would
still be met by the proposed changed method.  I doubt that obfuscating
the local part of an email address is an adequate measure of anonymization
or pseudonymization.  Similar concerns hold for phone numbers.
On a meta level mangled data is a threat to real data more than
replaced data is. FWIW, i don't see the special case for 'abuse-mailbox'.

With optimizing the 'dummification algorithm' around fuzzy criteria
it occurs to me we're putting the cart before the horse.

-Peter