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[members-discuss] is the RIPE NCC GDPR compliant ?
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Felipe Victolla Silveira
ripencc-management at ripe.net
Fri Feb 22 16:59:28 CET 2019
Hi Elvis, As I mentioned previously, we have been working on the issues you mention. You note that you have seen no progress on the ticketing issues. I can let you know that we have investigated all the options you mention (and more). Unfortunately, all options have some negative impacts and cause complexities for both the RIPE NCC and people who want to contact us. Granular-level reporting on our progress is not always possible or useful, especially as much of this work involves assessment of all options before a decision can be made. Reporting to our members while work is ongoing can be problematic, as it can create false expectations or spark discussion on outcomes that might not take place. We have heard all of your comments on our ticketing system and you can be sure we will factor them into our work. The Executive Board, which follows this list closely, is also made aware of our progress on a regular basis. We will also present our operational update at RIPE 78, and we will be sure to include further details then. Regarding the creation of objects in the RIPE Database, it’s important to be clear that here we are providing assistance for new RIPE NCC members. Objects are created by automated tooling, on behalf of the members, with the information they provide. Our tooling does not use the LIR's maintainer for authorising the creation or modification of objects. We are confident that we provide them with clear information on how the data they enter will be used and how they may update or delete it. In 2008, the Data Protection Task Force decided that there was a requirement to have personal data in the database. The RIPE Database Working Group has suggested that it is time to revisit this analysis and we agree with this assessment. However, it would not be appropriate for the RIPE NCC to unilaterally determine whether PERSON objects are needed. We will therefore follow the community’s lead. The discussions in the Database Working Group and elsewhere will ultimately inform all the decisions we take regarding personal data in the RIPE Database. And with multiple LIRs, it was not at all clear for a long time that the ability to create multiple LIRs would exist indefinitely. Indeed, the Executive Board prevented this via a resolution for a period until it became obvious that this led to people establishing new legal entities. The RIPE Database was set up to manage entries on an LIR basis, and it is not clear that changing this would be beneficial for RIPE Database users. Kind regards, Felipe Victolla Silveira Chief Operations Officer RIPE NCC
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