[db-wg] 2022-01 V2 Resource Holders Address

Colleagues

I have listened to your comments in recent discussions and had some
preliminary talks with the RIPE NCC about what could be implemented. So now
we have a second version of my proposal on personal data.

I was getting comments from people that LEAs need addresses for their
investigations, but also people had serious privacy concerns about
publishing their home address in the database. I was considering the idea
of publishing addresses with restricted access. However it seems that  it
is almost impossible to confirm the identity of LEAs (even from within our
own region, never mind globally) and perhaps other NGOs that could be
eligible to access this restricted data. So that idea is not viable.

Then there was an issue over data quality of the addresses currently
published in the database. In the ORGANISATION object the address is
assumed to be a postal address. This mandatory address is entered and
managed by the resource holders. No verification is done on this address.
In the database documentation it says:
"This is a full postal address for the business contact represented by this
organisation object."
That could be anyone. They don't even need to be located in the country
where the organisation operates it's business. Being so loosely defined,
any kind of verification would be impossible. That makes this address
almost meaningless. It is on the same level as the "country:" attribute in
resource objects. It only has meaning to whoever manages the data. Also by
having this unverifiable address mandatory, we are almost inviting those
who don't want to be easily located to enter false data. Especially as it
is almost impossible to identify any of this postal address data as being
true or false.

I am therefore suggesting we make this postal address an optional
attribute. If any resource holder wishes to enter this optional postal
address they can do so. But if it is a personal address they must not enter
more than region and country. The full personal address of a natural person
must not be entered into the database in any object type. Optional data,
when provided, is more likely to be accurate. Making this address optional
is in line with a recommendation of the RIPE Database Task Force.

Some will still argue that false data is useful if 'bad actors' enter the
same false data in different places. That offers investigators an
opportunity to cross reference this (false) data over different objects
using the free text search facility of the database. In some cases this may
be the only way to make these data links. Doing this has many problems. We
cannot justify preserving false data in the database to allow some people
to use an 'accidental feature'. There is no guarantee the same false data
will be used in multiple places. There is a defined purpose of the database
that allows LEAs to use public information from the database as part of
their investigations. This purpose is actually about granting permission to
LEAs to use available data. It does not define any data to be published in
the database for the sole benefit of LEAs. So there is no purpose requiring
this postal address to be published in the database. Optional is therefore
a convenience for anyone who wishes to enter it.

cheers
denis
policy proposer
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