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<font face="monospace">Hi Denis, all,<br>
<br>
To recap the discussion on this topic: after it was first
suggested to introduce geofeed as a new attribute in the RIPE
Database, we raised some legal concerns related to its
implementation and suggested that technical restrictions are
required to minimise the associated legal risks. The main concerns
arose because providing geolocation information, including
geolocation information that might contain personal data, is not
covered under the current purposes of the RIPE Database. <br>
<br>
From the discussion on the RIPE Database Working Group mailing
list prior to RIPE 85, various feedback was provided on the use of
geolocation information and the reasons for which this is useful
for network and content operators. At the RIPE 85 Database Working
Group session, the Working Group chairs declared there was
consensus that geolocation is a purpose the RIPE Database has to
fulfil. They also asked for input on the process to follow for
amending the current RIPE Database Terms and Conditions and
working on a draft purpose. A draft purpose has now been
suggested, along with the question of whether this addresses all
legal concerns and if we can go ahead with the implementation of
the geofeed attribute.<br>
<br>
Having established that geolocation is a purpose and looking at
the proposed text, our advice is to make this more explicit and
explain why personal data may be processed for the purpose of
geolocation. We will work on updating the RIPE Database Terms and
Conditions in order to specify this. In line with the <a
moz-do-not-send="true"
href="https://www.ripe.net/about-us/legal/corporate-governance/adoption-process-for-ripe-ncc-corporate-documents">Adoption
Process for RIPE NCC Corporate Documents</a>, the proposed
amendments will have to be approved by the RIPE NCC Executive
Board. <br>
<br>
On the implementation side, we will discuss internally how we can
make it explicit when adding a geofeed attribute that the privacy
of the users of the related resources is respected. This is
necessary because, as mentioned in our previous replies, although
the RIPE NCC is not the party inserting the data in the csv file,
legally we are co-responsible for the information inserted in the
RIPE Database (even if it is not hosted there directly). As with
all the other personal data in the RIPE Database, the party that
enters it has the responsibility to inform the individual to whom
the data pertains and to obtain their explicit consent before
entering it (Art. 6.3 RIPE Database Terms and Conditions). <br>
<br>
Kind regards,<br>
<br>
Maria Stafyla<br>
Senior Legal Counsel<br>
RIPE NCC</font><br>
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<p></p>
<div class="moz-cite-prefix">On 25/04/2023 11:25, Maria Stafyla
wrote:<br>
</div>
<blockquote type="cite"
cite="mid:603685c5-fa3b-95c3-c5ff-c0af2cddcd4b@ripe.net">Hi Denis,
all
<br>
<br>
This is to confirm that we are already working on our analysis and
we will get back to you as soon as possible.
<br>
<br>
Kind regards,
<br>
<br>
Maria Stafyla
<br>
Senior Legal Counsel
<br>
RIPE NCC
<br>
<br>
On 13/04/2023 12:29, denis walker wrote:
<br>
<blockquote type="cite">Colleagues
<br>
<br>
A question for the legal team at the RIPE NCC. Would a simple
purpose,
<br>
as suggested below, address all the concerns you had about the
use of
<br>
the "geofeed:" attribute and allow you to remove any
restrictions you
<br>
felt were necessary when it was introduced?
<br>
<br>
cheers
<br>
denis
<br>
co-chair DB-WG
<br>
<br>
<br>
---------- Forwarded message ---------
<br>
From: denis walker <a class="moz-txt-link-rfc2396E" href="mailto:ripedenis@gmail.com"><ripedenis@gmail.com></a>
<br>
Date: Tue, 11 Apr 2023 at 10:41
<br>
Subject: Geofeed purpose
<br>
To: Database WG <a class="moz-txt-link-rfc2396E" href="mailto:db-wg@ripe.net"><db-wg@ripe.net></a>
<br>
<br>
<br>
Colleagues
<br>
<br>
The conversation on deploying geofeed died shortly after RIPE
85. The
<br>
last comment was from myself asking if anyone was willing to
propose
<br>
some wording for a new purpose covering the use of the RIPE
Database
<br>
for geolocation information. No one proposed any wording. So
below I
<br>
have made a proposal for a new purpose. Your comments are
appreciated.
<br>
<br>
cheers
<br>
denis
<br>
co-chair DB-WG
<br>
<br>
<br>
The RIPE Database contains information for the following
purposes:
<br>
<br>
Ensuring the uniqueness of Internet number resource usage
through
<br>
registration of information related to the resources and
Registrants
<br>
Publishing routing policies by network operators (IRR)
<br>
Facilitating coordination between network operators
(network
<br>
problem resolution, outage notification etc.)
<br>
Provisioning of Reverse Domain Name System (DNS) and ENUM
delegations
<br>
Providing information about the Registrant and Maintainer
of
<br>
Internet number resources when the resources are suspected of
being
<br>
used for unlawful activities, to parties who are authorised
under the
<br>
law to receive such information.
<br>
Scientific research into network operations and topology
<br>
Providing information to parties involved in disputes over
<br>
Internet number resource registrations to parties who are
authorised
<br>
under the law to receive such information.
<br>
<br>
<br>
Providing information about the geolocation usage of Internet
number resources.
<br>
</blockquote>
</blockquote>
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