[dp-tf] Authorization to publish personal data in the DB (was Re: [dp-tf] Quadlogy of person proposals)

Dear Larisa,

>>>Let's look if the RIPE Database rules comly with it.
>>>For example, Section II, "CRITERIA FOR MAKING DATA PROCESSING LEGITIMATE"
>>>
>>>1. Member States shall provide that personal data may be processed only if:
>>>(a) the data subject has unambiguously given his consent; or
>>>
>>>No. admin-c and tech-c are mandatory, without any personal consent
>>
>>I am not sure this is the right way of putting it.
>>Yes, admin-c and tech-c _are_ mandatory, however, nobody
>>says you may (or even worse: you should) publish such data
>>without the given person's consent. In fact we never did so,
>>and I am sure many other people did not do so either.
> 
> 
> ripe-252 states what contact information is:
> 
> "details of people who are responsible for the operation of networks
> or routers, and those who are responsible for maintaining information in the RIPE Database."
> 
> Or the person responsible for all that either not responsible.
> If the person is responsible, he/she must be published.

Again, this is not the proper way to put it.

Nobody can oblige you to breach the law. You have to
publish the data of a person responsible for the
operations/maintenance. If within an organization
somebody does not accept to have his/her data published,
they have to appoint an other person who assumes this
responsibility and accepts to have his/her data
published.

> If you have never did so, - very bad! :)

What I said is: we never published personal data without the
given person's consent. I do not think this was bad. :)



>>The idea is that you have to find a person who consents to
>>this, and only publish his/her data.
>>
>>
>>>So, WHAT MAKES PERSONAL DATA PROCESSING IN THE RIPE DB LEGITIMATE?
>>
>>I think you are right, the only paragraph that may apply is
>>(a) above. What we have to make sure is that people act in
>>accordance with it.
>>
>>Best regards,
>>Janos
>>
>>
> 
> 
> 
> With respect,
> Larisa Yurkina
> ---
> RIPN Registry center
> -----