[ncc-services-wg] sara proposal and question to Randy

Dear All,

regarding message 1 : If we all agree that personnal ie individual data
has to be removed from direct access and that the legal address has to
be published, I would say that on an investigative view, it doesn't
always matter who we are asking for some data. For sure it helps knowing
who is working within any company especially when you are questionning
yourself wether the company is a fraud or not but this is not the majority.
I would say that what is important to get an idea of how big the company
is. Are we going to request the CEO ? The legal adviser (if he exists) ?
Maybe wihtin the unit or office in charge of dealing with requests could
be published too.


To randy, I would like to say that I don't understand what he pmeans by
"whois is useless and should die".
As I am new in this group, I might have missed something. Could you
explain what you mean ?

regards


cv

Pour une administration exemplaire, préservons l'environnement.
N'imprimons que si nécessaire.

-------- Message original --------
*Sujet: *[INTERNET] ncc-services-wg Digest, Vol 79, Issue 3
*De : *ncc-services-wg-request at ripe.net
*Pour : *ncc-services-wg at ripe.net
*Date : *09/10/2018 12:00
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> Today's Topics:
>
>    1. @EXT: 2018-05 New Policy Proposal (Publication of Legal
>       Address of Internet Number Resource Holder) - updating the
>       proposal? (Marcolla, Sara Veronica)
>    2. Re: @EXT: 2018-05 New Policy Proposal (Publication of Legal
>       Address of Internet Number Resource Holder) - updating the
>       proposal? (Randy Bush)
>    3. Re: @EXT: 2018-05 New Policy Proposal (Publication of Legal
>       Address of Internet Number Resource Holder) - updating the
>       proposal? (Carlos Fria?as)
>    4. @EXT: RE: 2018-05 New Policy Proposal (Publication of Legal
>       Address of Internet Number Resource Holder) - updating the
>       proposal? (Marcolla, Sara Veronica)
>    5. Re: @EXT: 2018-05 New Policy Proposal (Publication of Legal
>       Address of Internet Number Resource Holder) - updating the
>       proposal? (Nik Soggia)
>
>
> ----------------------------------------------------------------------
>
> Message: 1
> Date: Mon, 8 Oct 2018 15:46:47 +0000
> From: "Marcolla, Sara Veronica" <Sara.Marcolla at europol.europa.eu>
> To: "'ncc-services-wg at ripe.net'" <ncc-services-wg at ripe.net>
> Subject: [ncc-services-wg] @EXT: 2018-05 New Policy Proposal
> 	(Publication of Legal Address of Internet Number Resource Holder) -
> 	updating the proposal?
> Message-ID:
> 	<ED32B03A4D1A7448B86844EED9D4845D4EA5BF82 at COIMBRA.europol.eu.int>
> Content-Type: text/plain; charset="us-ascii"
>
> Hi everyone,
>
> 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. 
>
> 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.
>
> Looking forward to hear the feedback to this idea for an amendment to the proposal. 
>
> 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.
>
> *******************
>
>
>
>
> ------------------------------
>
> Message: 2
> Date: Mon, 08 Oct 2018 09:30:39 -0700
> From: Randy Bush <randy at psg.com>
> To: "Marcolla, Sara Veronica" <Sara.Marcolla at europol.europa.eu>
> Cc: "'ncc-services-wg at ripe.net'" <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?
> Message-ID: <m2y3b8e6z4.wl-randy at psg.com>
> Content-Type: text/plain; charset=US-ASCII
>
>> At this point I am asking whether you support a proposal, the
>> clarifies that only the legal address of companies will be published
> not particularly
>
> the contract is between the ncc and the registrant; not the community
> and the registrant.
>
> whois (not the irr, which is confuddled with it in the ripe registry)
> is useless and should die.
>
> randy
>
>
>
> ------------------------------
>
> Message: 3
> Date: Mon, 8 Oct 2018 22:50:25 +0100 (WEST)
> From: Carlos Fria?as <cfriacas at fccn.pt>
> To: "Marcolla, Sara Veronica" <Sara.Marcolla at europol.europa.eu>
> Cc: "'ncc-services-wg at ripe.net'" <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?
> Message-ID:
> 	<alpine.LRH.2.21.1810082238040.25543 at gauntlet.corp.fccn.pt>
> Content-Type: text/plain; charset=US-ASCII; format=flowed
>
>
>
> 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.
>>
>> *******************
>>
>>
>
>
> ------------------------------
>
> Message: 4
> Date: Tue, 9 Oct 2018 07:41:15 +0000
> From: "Marcolla, Sara Veronica" <Sara.Marcolla at europol.europa.eu>
> To: 'Carlos Fria?as' <cfriacas at fccn.pt>, "'ncc-services-wg at ripe.net'"
> 	<ncc-services-wg at ripe.net>
> Subject: [ncc-services-wg] @EXT: RE: 2018-05 New Policy Proposal
> 	(Publication of Legal Address of Internet Number Resource Holder) -
> 	updating the proposal?
> Message-ID:
> 	<ED32B03A4D1A7448B86844EED9D4845D4EA5C59B at COIMBRA.europol.eu.int>
> Content-Type: text/plain; charset="iso-8859-1"
>
> 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 Fria?as [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.
>
> *******************
>
>
>
>
> ------------------------------
>
> Message: 5
> Date: Tue, 9 Oct 2018 10:13:48 +0200
> From: Nik Soggia <registry at telnetwork.it>
> To: "'ncc-services-wg at ripe.net'" <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?
> Message-ID: <e3905e73-8c1d-6784-e3a5-aacf47215507 at telnetwork.it>
> Content-Type: text/plain; charset=iso-8859-15; format=flowed
>
> Il 08/10/18 17:46, Marcolla, Sara Veronica ha scritto:
>
>> 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.
> Maybe the key to make everyone happy is the word "can" instead of 
> "must". Why not make it optional?
>
> If companies are in good faith or they like the idea then they will use 
> it, and they will also be happy to maintain the data.
> Otherwise it will be just a waste of time on another 
> wrong/outdated/malicious dataset.
> How fun it is to check the validity of a validated address?
> Life is too short, right?
>
>> This legal address is usually publicly available anyhow and can be then validated by the RIPE NCC.
> Duplicating data instead of referencing it breaks the first database 
> design rule.
> Companies are forced by law to keep their chamber of commerce data up to 
> date. THAT is the best source of information and it is readily 
> available. Don't reinvent the wheel.
>
> This proposal is can of worms:
> - same data in many places is difficult to maintain and prone to errors
> - doesn't stop bad actors
> - quickly provides massive information to data harvesters and scammers
>
> In my opinion this proposal is not the right way to identify a resource 
> holder the way you dreamt.
> It's not a elegant solution and in general I have a bad feeling about 
> it, imagine a blunt tool that not only will make a poor job but also 
> will bring a lot of frustration.
>
> Ok for me if it is optional, otherwise I'm against.
> Regards,
>

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