[db-wg] Fwd: proposal: new attribute 'geofeed:

Hi,
(just my two cents)

At the GDPR trainings/sessions i have been a part of, there is the 
"purpose" bit in GDPR. One natural person can choose to publish 
(its own) personal data if there is a purpose for it. In the RIPEdb case, 
the purpose seems obvious: 
to provide a worldwide reachable contact for a given resource.

Also, if someone uses the same phone# for personal *and* business 
purposes, the choice to use that phone# or to find another exclusively 
business-oriented phone# should be that someone's choice...

Regards,
Carlos



On Wed, 27 Jan 2021, denis walker via db-wg wrote:

> HI Maria
>
> Thanks for the preliminary analysis. I do have a couple of questions below...
>
> On Wed, 27 Jan 2021 at 09:21, Maria Stafyla <mstafyla at ripe.net> wrote:
>>
>> Hi Denis, all,
>>
>> Thank you for your patience in this matter.
>>
>> We looked into this and the answer varies depending on the situation.
>>
>> Allocations and assignments can be made to either natural or legal persons. In the inetnums and inet6nums to be created the contact details of the relevant person will be inserted.
>>
>> For example, if a /27 IPv4 block is assigned to a legal person, the geofeed data will likely not constitute personal data. This will not be the case if an IPv4 /32 (single IP address) is assigned to a sole trader and the assignment is registered under the sole trader's name in the RIPE Database*. In this latter example, the inetnum will contain the contact details of the sole trader and the geofeed data will qualify as personal data.
>>
>> This is because personal data under GDPR is defined as any information that relates to an identified or identifiable natural person.
>>
>
> So in this situation, if this sole trader has a phone used exclusively
> for the business and a business email address and these are listed as
> their business contact details, are you saying the business phone and
> email are still classed as personal data? If that is true then
> anything 'relating' to the business is also 'relating' to the natural
> person and is therefore personal data.
>
> cheers
> denis
> co-chair DB-WG
>
>
>> Based on the above and before introducing the geofeed attribute, a full impact analysis of its implementation would have to be conducted by the RIPE NCC.
>>
>> If you have any questions, please let us know.
>>
>> Kind regards,
>>
>> Maria Stafyla
>> Senior Legal Counsel
>> RIPE NCC
>>
>>
>> * Please note that the relevant RIPE Policy (https://www.ripe.net/publications/docs/ripe-733#62) is allowing not to register assignments on the end user's contact details but as part of the service provider's internal infrastructure.
>>
>>
>> On 08/01/2021 11:27, Maria Stafyla wrote:
>>
>> Hi Denis, all
>>
>> Please allow us some time to look into this and we will get back to you
>> with our feedback next week.
>>
>> Kind regards,
>>
>> Maria Stafyla
>> Senior Legal Counsel
>> RIPE NCC
>>
>>
>> ---------- Forwarded message ---------
>> From: denis walker <ripedenis at gmail.com>
>> Date: Thu, 7 Jan 2021 at 15:59
>> Subject: Re: [db-wg] Fwd: proposal: new attribute 'geofeed:
>> To: Hank Nussbacher <hank at interall.co.il>, <legal at ripe.net>
>> Cc: Database WG <db-wg at ripe.net>
>>
>>
>> HI Hank, colleagues
>>
>> Whilst I can't answer your basic question, I could say that if the
>> IETF approves a change to RPSL, with the RIPE Database data model
>> based on RPSL, in principle we should implement the RPSL change.
>>
>> Perhaps another question, to the RIPE NCC legal team, if I have a
>> fixed IP address or block of addresses, is this geofeed location data
>> personal data under the terms of GDPR?
>>
>> cheers
>> denis
>> co-chair DB-WG
>>
>> On Wed, 6 Jan 2021 at 07:01, hank--- via db-wg <db-wg at ripe.net> wrote:
>>
>> I guess I am not understanding something.
>> Why do we need a geofeed attribute?  What problem are we trying to solve?
>>
>> I understand why each block of IPs needs to be associated with a
>> country, so that certain language specific auto-customizations will
>> work.  But what purpose is there to know that a /24 is in central
>> Amsterdam?  Is the purpose to assist marketers in geo-targetted sales?
>>   Is the purpose for network engineering (not sure what major problem
>> we have that needs this)?
>>
>> Is the purpose to know where you are so that in the event of an
>> emergency (terror, tornado, etc) you can get emergency targeted
>> alerts?  If so, then the geofeed has to be at the /32 level and since
>> many if not most IPs are mobile, and that is where you will get the
>> alert from - from your cellphone provider, I still don't quite
>> understand the reason for a geofeed tag.
>>
>> Can someone clue me in?
>>
>> Thanks,
>> Hank
>>
>> Caveat: The views expressed above are solely my own and do not express
>> the views or opinions of my employer
>>
>>
>