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

Hi Nick

I am preparing a reply to your comments. I need to do some research to give
you a full response. This week I'm in a rural French village with virtually
no Internet connectivity. So a quick response is unlikely.

cheers
denis
Proposal author

On Sun, 19 Jun 2022, 16:06 Nick Hilliard, <nick at foobar.org> wrote:

> denis walker via db-wg wrote on 16/06/2022 16:05:
> > 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.
>
> There are some fairly serious structural issues with the justification
> in this proposal, for example:
>
> - that there's something new with GDPR that wasn't there before
> - that the RIPE database is not GDPR compliant
> - repeated claims that "In almost all cases, personal data is not needed".
> - etc
>
> GDPR, and previously the 1995 Data Protection Directive, has been
> addressed continuously by the RIPE NCC over the years.  There are some
> blog posts on the RIPE NCC web site which provide an overview of the
> current lawful basis for holding and publishing the information:
>
> >
> https://www.ripe.net/about-us/legal/corporate-governance/gdpr-and-the-ripe-ncc
>
> So in the absence of firm reasoning to the contrary, this policy needs
> to step back quite far from claiming or hinting at GDPR non-compliance.
>
> There are numerous other cases where the current justification presents
> opinions without providing an adequate factual basis.
>
> Incidentally, I'm not arguing that there shouldn't be changes to the
> scope and style of information contained in the ripe database, but as it
> stands, the scope of this policy proposal isn't justified by the
> rationale provided.
>
> Nick
>
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