[db-wg] Publishing Deleted Objects - Legal Analysis

Hi Niall

On 02/06/2015 16:49, Niall O'Reilly wrote:
> On Tue, 02 Jun 2015 14:36:21 +0100,
> Athina Fragkouli wrote:
>> If the RIPE community wishes to have access to contact details of
>> individuals that were responsible for resolving operational problems in
>> the past, then the RIPE community must have a specific, explicitly
>> defined and legitimate purpose for it. If such a purpose is defined, the
>> RIPE NCC will proceed with investigating the conditions under which this
>> feature can be implemented in compliance with the Act. Implementation of
>> this feature may include prior consent of these individuals.
>    Thanks, Athina.
>
>    IIUC, if such a purpose as "maintaining a historical record" were
>    defined, the relevant data subjects would have to opt in before
>    their details could be included.  Is that it?


Two of the existing purposes partially cover this:

- Providing information about the Registrant and Maintainer of Internet 
number resources when the resources are suspected of being used for 
unlawful activities, to parties who are authorised under the law to 
receive such information.

- Providing information to parties involved in disputes over Internet 
number resource registrations to parties who are authorised under the 
law to receive such information.

These allow for the NCC to retain this information (maintain a 
historical record) for investigations or disputes that may arise in the 
future over historical resources. But neither allow for this historical 
information to be made publicly available in respect of personal data or 
(referring to my previous email) data used purely for the management of 
operational data.

cheers
denis


>
>    ATB
>    Niall
>    
>

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