[db-wg] 2022-01 New Version Policy Proposal (Personal Data in the RIPE Database)

Hi Ronald

Nice to read that you vigorously support parts of my policy proposal at
least.

On Thu, 23 Jun 2022, 10:39 Ronald F. Guilmette via db-wg, <db-wg at ripe.net>
wrote:

> In message <YrLp+ZTtuw+93KR/@jima.tpb.net>,
> Niels Bakker <niels=dbwg at bakker.net> wrote:
>
> >The current proposal is also a solution to people entering wrong
> >information, as denis has clearly stated. Bad information in the
> >database should be avoided, it's worse than no data.
>
> Wow!  I confess that I didn'rt read sections 4.0, 5.0, and 6.0 of this
> proposal (2022-01) till now.
>
> This is REALLY astonishing!  For a proposal that is initially billed as
> one for which the need "arises from the need for the RIPE Database to
> avoid the publishing of unnecessary personal data" this proposal veers
> quite dramatically and vastly off-course in sections 4.0, 5.0, and 6.0
> as it attempts to contstruct a whole new and never-before-seen regime
> to "verify" *all* WHOIS data... presumably for some value of "verify".
>

The policy proposal is about processing personal data. That easily covers
verifying that entered data is correct. It does not cover verification of
'all' data. Only the clearly specified data.


> Who exactly is going to be tasked with verifying 100% of the names, email
> addresses, phone numbers, and street addresses already present in the data
> base and what procedures and criteria will be used for this process?  Will
> NCC be tasked to do this huge amount of work?  Is there a a target
> completion
> date?  2029 perhaps?
>

Not all these data elements are covered and not 100% of others either. As
you pointed out, some of the data elements you mention above cannot be
verified and that's why they are not covered.


> Even above and beyond the huge amount of work this proposal would create
> for -somebody-, the practical challenges all seem to be left as an exercise
> for the reader.
>
> How exactly does one "verify" a voice phone number?
>
> How exactly does one "verify" a mailing address?
>

How data can or should be verified is an implementation issue. This policy
proposal is concerned with establishing principles.


> As should already be apparent I am 100% in favor of *all* of this kind of
> "verification", and indeed, I am very much looking forward to it all being
> done.  But as noted above, there are a LOT of unanswered questions
> regarding
> how, when, and by whom this will all be done.  And that is -before- we even
> get into the question of what the plan is to -force- existing members...
> not
> even to mention legacy holders... to have accurate WHOIS info if they just
> don't much feel like it.  How can existing members be forced into this if
> their existing contracts do not already require it?  And what will be the
> penality imposed upon any member who refuses to go along?  Expulsion from
> RIPE and/or termination of their membership??  That is sure to be wildly
> popular among the membership... NOT!
>

This policy proposal, quite correctly, makes no mention of cancelling
membership or de-registering any resources. Just as the abuse-c policy
doesn't. It is about establishing the principles that will govern the way
data is processed. Most RIPE policies don't define enforcement procedures.
That is clearly outside the scope of defining principles.

All members and contracted resources are already bound by agreements that
require them to enter correct data into the database.


> None of these questions are answered by the proposal.  Again, all of these
> questions are left as an exercise for the reader.  I don't see how this
> propsal can fly, given that it fails to even try to answer any of the
> obvious questions it raises.
>

Because that will be discussed along with any other implementation details.


> Furthermore, as I've said, sections  4.0, 5.0, and 6.0 of this proposal are
> quite clearly entirely unrelated to the goal of *removing* personal data
> from the data base.  So really, what we have here is two entirely unrelated
> proposals... one for removal of some data and another for the verification
> of other data... glued together to make them superficially appear to be
> just a single proposal.
>

This policy proposal is not specifically about removal of personal data. In
the abstract it says:

"This policy sets out the principles governing the publishing of personal
data in the RIPE Database. These principles must be applied to all personal
data published in the database by all data maintainers"



> I'm frankly not sure that it is even worth further discussion of this
> proposal
> until such time as it is broken into two propsals by its author... one for
> removal of personal data from WHOIS, which I remain adamantly opposed to,
> and a separate one for verification of WHOIS data, which I vigorously
> support.
>

As I said above, this policy proposal is about establishing the principles
by which personal data is processed. If these principles are accepted there
will need to be quite a discussion to follow on how to implement these
principles and what type of migration plan will be needed. It is quite
clear no one will flick a switch and all these changes will happen over
night. It is also clear that a migration plan will need to include many
steps allowing time for members to adapt and adjust.

Cheers
denis
Proposal author


>
> Regards,
> rfg
>
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