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

Hi Carlos,

I understand the logic behind the protection of LIRs for competition reasons - however I am positively sure that this right cannot be considered anywhere close to the right to privacy and protection of individuals.

Regarding your comment on the company change, I believe that the case of change of holdership should firstly have  to pass the existing RIPE NCC due diligence checks for transfers/mergers. It would then  still be useful to actually have the legal address of this new company, as it helps to identify the company who is the registered resource holder.

Sara

-----Original Message-----
From: Carlos Friaças [mailto:cfriacas at fccn.pt] 
Sent: 08 October 2018 23:50
To: Marcolla, Sara Veronica
Cc: 'ncc-services-wg at ripe.net'
Subject: Re: [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
> *******************
>
> DISCLAIMER : This message is sent in confidence and is only intended for the named recipient. If you receive this message by mistake, you may not use, copy, distribute or forward this message, or any part of its contents or rely upon the information contained in it.
> Please notify the sender immediately by e-mail and delete the relevant e-mails from any computer. This message does not constitute a commitment by Europol unless otherwise indicated.
>
> *******************
>
>

*******************

DISCLAIMER : This message is sent in confidence and is only intended for the named recipient. If you receive this message by mistake, you may not use, copy, distribute or forward this message, or any part of its contents or rely upon the information contained in it.
Please notify the sender immediately by e-mail and delete the relevant e-mails from any computer. This message does not constitute a commitment by Europol unless otherwise indicated.

*******************