[ncc-services-wg] @EXT: 2018-05 New Policy Proposal (Publication of Legal Address of Internet Number Resource Holder) - updating the proposal?

On Mon, 8 Oct 2018, Marcolla, Sara Veronica wrote:

> Hi everyone,

Greetings,


> All the comments exchanged in the list made me thinking a lot about the 
> wording of this proposal. I have noticed that the lively discussion 
> around the policy is bringing a lot of attention on the dichotomy 
> between the individual (which I agree completely, should be protected 
> in their fundamental rights, with provisions such as the GDPR and 
> others), and the company/corporation. It seems to me so far that many of 
> us would indeed support the idea of having the legal address published 
> of companies, but having concerns about personal data. The aim of this 
> proposal is indeed to focus on companies, not individuals, and even the 
> smallest company has to be registered as such (if not for other reasons, 
> for tax reasons). Individuals will be anyways protected by a 
> hierarchically higher set of rules: the fundamental rights, such as 
> those championed by GDPR for example.

Well, LIR addresses are already published on the RIPE NCC's website.
LIR's customers addresses may not be part of whois.ripe.net... well... 
i know some LIRs tend to protect their customers identity, to prevent 
competitors to approach them with better contractual conditions (this is 
not the case of the LIR i work for, which is a NREN)


> At this point I am asking whether you support a proposal, the clarifies 
> that only the legal address of companies will be published, and that 
> states clearly that individuals information will be protected? After 
> all, the reasoning here is that if a resource holder is registered with 
> a national company registry, they have a legal address which can be 
> published. This legal address is usually publicly available anyhow and 
> can be then validated by the RIPE NCC.

I see added value in "validation by the RIPE NCC", despite the natural 
cost this will bring...

However, i wonder what should be the procedure if RIPE NCC finds that 
company X registers a new company Y in a different country/economy 
resorting to a "virtual office" address.


> Looking forward to hear the feedback to this idea for an amendment to the proposal.

Good luck!


Best Regards,
Carlos


> Sara
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