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

Hi Cynthia and Peter

You both raise some interesting points and I will address them all in
one email. Let's start with 'why' do we publish the name and address
of resource holders. The RIPE Database is one of a set of 5 databases
that collectively document the registration of all global internet
resources. This is to offer to the public an open source of the 'who'
is using internet resources. Only by offering this information openly
can we have accountability at all levels of society. If this
information is closed with restricted access then accountability can
only be judged and enforced by lawful authorities.

So let's look in more detail at the consequences of open vs closed
data. This only applies to the name and address details of resource
holders who are natural persons as well as end users operating public
networks with assignments. No other personal data should even be
considered in this database.

In an open system the names and addresses of all internet resource
holders and public network operators are published. In an ideal world
all this data will be verified and accurate. This makes it easy for
anyone who is following up on criminal activity or abuse on the
internet to look up who is using a particular (block of) addresses.
This is not only LEAs. Private organisations and individuals can also
follow up abuse and take civil actions against the abusers.

In a closed system we don't publish names or addresses of natural
people. The information will be held by the RIPE NCC or a member or a
sub allocation holder, or ... This gives maximum privacy protection
for natural persons, but causes problems for anyone trying to address
criminal activities or abuse on the internet. This arrangement can be
further manipulated by the bad actors to hide their tracks. Suppose a
natural person in country A becomes a member. Their details are not
published. They sub-allocate to a natural person in country B who
assigns to a natural person in country C. None of their details are
published. If this assignee is an abuser, an LEA, or other
organisation, has to get a court order in the Netherlands to get the
details of the resource holder in country A from the RIPE NCC. Then
they need a court order in country A to get the details of the sub
allocation holder. Then they need a court order in country B to get
the details of the assignee. If we go down this closed system route we
may have to look at who has a right to this information (which is
currently public) and how....but that is outside the scope of this
policy proposal.

Another option, where a resource holder is a natural person, is to
'require' them to have an official, legal address such as an
accountant or lawyer office, with their consent to publish that (non
personal) address.

Having a simple rule like 'we don't publish names or addresses of
natural persons' is easier to apply and less error prone. But we are
turning the RIPE Database into more like a domain registry where lots
of details are hidden from public view. Does this affect the
usefulness of the RIPE Database as a public registry?

I think it is a good idea to extend the scope of this policy to
include anywhere that the RIPE NCC publishes personal details of
members. So it would include the web pages where members are listed.

cheers
denis

On Fri, 13 May 2022 at 00:56, Cynthia Revström via db-wg <db-wg at ripe.net> wrote:
>
> Hi,
>
> I am generally in support of this policy, however I do wonder why
> publish legal names of individuals in the cases of natural persons
> holding resources?
>
> Like why can't it just be some alias and the real name needs to be
> requested from the RIPE NCC by court order or whatever would be
> required for physical addresses under this proposal.
>
> While my name is a bad example, there are plenty of names that are
> extremely common, and if all that is published is the name and
> country, is it really all that useful?
> It is not like knowing that it is someone in the United States with
> the name "Joe Smith" is particularly useful on its own to know who it
> is.
> But on the other hand in such cases it is not a big privacy problem I suppose.
>
> However with a name like mine it is a privacy concern as my name is
> not exactly common.
>
> I would like to hear what the reason would be for requiring this to be
> published if it is either kinda pointless information or still a big
> privacy issue.
>
> Also I have a kinda Sweden-specific question about the following part
> (from 1.0 Organisations):
> > personal address for the organisation which is already in the public domain in a national, public, business registry.
>
> In Sweden there are multiple private organizations that publish home
> addresses for almost everyone in the country by combining some quirks
> of the freedom of the press act and government transparency.
> Would this count according to that, and as such would you say it is
> okay to publish the personal addresses for almost everyone in Sweden?
> The government doesn't directly publish this information, people have
> no right to demand to be excluded but it is still public.
> The important thing here though imo is that these websites generally
> are a lot harder to scrape than the RIPE Database.
>
> Also what if it was an address that was kinda public but you had to
> create an account and agree to not re-publish it elsewhere, would that
> make it okay or not okay to publish?
> Or what if that address is published somewhere, but not linked to that
> person's name, maybe it is linked to some unrelated legal entity that
> is on the same address, would that make it okay to publish?
>
> I think it would be a lot easier to just say that personal addresses
> should never be published.
> Just because it is already somewhere on the internet doesn't mean that
> the RIPE Database has to spread it further.
>
> -Cynthia
>
> On Tue, May 10, 2022 at 11:29 AM Angela Dall'Ara via db-wg
> <db-wg at ripe.net> wrote:
> >
> > Dear colleagues,
> >
> > A new RIPE Policy proposal, 2022-01, "Personal Data in the RIPE Database"
> > is now available for discussion.
> >
> > The goal of this proposal is to allow the publication of verified Personal Data in the RIPE Database only when they are justified by its purpose.
> >
> > You can find the full proposal at:
> > https://www.ripe.net/participate/policies/proposals/2022-01
> >
> > As per the RIPE Policy Development Process (PDP), the purpose of this four week Discussion Phase
> > is to discuss the proposal and provide feedback to the proposer.
> >
> > At the end of the Discussion Phase, the proposer, with the agreement of the WG Chairs, will decide how to proceed with the proposal.
> >
> > The PDP document can be found at:
> > https://www.ripe.net/publications/docs/ripe-710
> >
> > We encourage you to review this proposal and send your comments to
> > db-wg at ripe.net  before 8 June 2022.
> >
> >
> > Kind regards,
> >
> > Angela Dall'Ara
> > Policy Officer
> > RIPE NCC
> >
> >
> > --
> >
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