[db-wg] Locking unmaintained PERSON and ROLE objects in the RIPE Database

Dear Denis, all,

The RIPE NCC is by default the "data controller" of the personal data in the Database (i.e. it has liability by law) but in practice it has no control over all these personal data. The Data Protection Task Force, representing the RIPE community, decided that this responsibility should be contractually (via the RIPE Database Terms and Conditions) transferred to those that have actual control over the personal data.

In the RIPE Database, these persons are identified by the maintainer object (referenced by the “mnt-by:” attribute in any data object). The Data Protection Task Force decided that this attribute should be made mandatory for all objects. This attribute would be used to indicate who is really responsible for specific personal data in the RIPE Database. Additionally, the Data Protection Task Force decided that the RIPE NCC should remove all unreferenced personal data from the RIPE Database.

Although the RIPE NCC allowed some time for the community members to add a mandatory "mnt-by:" to their so-far unmaintained personal data, there were still unmaintained personal data in the RIPE Database. The RIPE NCC was alerted by third parties that this data could be hijacked in order to facilitate illegal activities.

It was the RIPE NCC's responsibility to inform the RIPE community of this security risk and initiate a community discussion on possible ways to handle it. At the same time, the RIPE NCC could anticipate that if we were merely exposed the security risk without taking any measures to prevent it, we would alert malicious people and the hijacking attempts would increase.

Therefore, we considered that locking the objects, until the community could discuss a proper way forward, would be an adequate measure to prevent possible hijacking cases in the meantime, without creating a disproportionate burden for legitimate holders. This action was in line with the RIPE NCC's obligations by law.

If people would like to have their locked personal data removed from the RIPE Database, they can submit a request to the RIPE NCC.

Kind regards,

Athina Fragkouli
Head of Legal
RIPE NCC


References:
RIPE Database Terms and Conditions
https://www.ripe.net/manage-ips-and-asns/db/support/documentation/terms 

DPTF report
https://www.ripe.net/participate/ripe/tf/dp/report-of-the-ripe-data-protection-task-force

Data Protection report
https://www.ripe.net/about-us/legal/ripe-ncc-data-protection-report 

Procedure for the Removal of Personal Contact Details from the RIPE Database
https://www.ripe.net/manage-ips-and-asns/db/support/documentation/removal-of-personal-data