[db-wg] NWI-13 Geofeed Legal Analysis

Hi,

On Thu, Jul 28, 2022 at 01:33:07PM +0200, Maria Stafyla via db-wg wrote:
> As mentioned in the Legal Review Impact Analysis, if the geofeed 
> attribute is inserted for registrations of assignments that are 
> reasonably assumed to be related to one individual user, then the 
> attribute will be considered as containing personal data and GDPR will 
> apply. This is why we have proposed to implement restrictions.

I maintain that this part of the analysis is fundamentally flawed.

The size of an assignment does not have any correlation to the entity
that the prefix is assigned to - we can assign IPv4 /32s to corporate
customers, and we can assign IPv4 /28s to private end users, and this
is perfectly within the scope of the relevant RIPE policies.

Inventing restrictions based on "but it looks like!!" guesswork is
not what we are paying the RIPE NCC for.

*Especially* as the information entered is not PII itself, but 
a pointer to a URL which could, as has been stated, contain anything
from "ZZ" to very detailed addresses, fully under control and fully
in the responsibility of the entity maintaining that list.


I have the nagging suspicion that people are not listening here, because
all this was already said months ago, and we're still running in circles.

Gert Doering
        -- totally not interested in geofeed:, but annoyed by arbitrary
           restrictions not in line with RIPE policies
-- 
have you enabled IPv6 on something today...?

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