Openness about Policy Violations

Summary of Proposal

The RIPE NCC is the membership organisation that manages the shared public resources of IP addresses and Autonomous System Numbers in its service region.  This proposal makes complaints about delegated resources more visible.  It also specifies a separate list that documents all reclaimed resources.

The goals are to provide more insight into the good stewardship of the RIPE NCC and to encourage assistance in stopping abuse of these shared public resources.

This proposal explicitly does not set or change any policies about assignment, allocation or revocation of these resources.

New policy text

[Following text will result in a new RIPE Policy Document “Policy Violation Reports” ]

Abstract

The RIPE NCC is the membership organisation that manages the shared public resources of IP addresses and Autonomous System Numbers in its service region.  This policy requests the RIPE NCC to publish statistics on complaints about resources.  It also specifies a separate list that documents all reclaimed resources.

1. Transparency on reported policy violations

The RIPE NCC accepts reports about Internet number resource registrations such as violation of RIPE Policies and RIPE NCC Procedures, provision of untruthful information to the RIPE NCC, bankruptcy, liquidation or insolvency of resource holders and incorrect contact information in the RIPE Database.

The RIPE NCC will handle all such reports and publish statistics about such reports publicly.

The RIPE NCC will publish regularly statistics of the reports that have been received but not yet closed. These statistics will show the number of reports in each of the following categories:

• 'new': Submitted but not being investigated yet      
• 'under-investigation': The RIPE NCC is investigating the report 

In addition to these running totals the RIPE NCC publishes statistics about how these reports have been closed. These statistics are divided into the following categories:   

• 'closed, out-of-scope': The report is out of scope for the RIPE NCC reporting system        
• 'closed, resolved-by-holder': The resource holder has resolved any problems   
• 'closed, resources-returned': The report has led to resources being returned to the RIPE NCC  
• 'closed, no-violation': After investigation the RIPE NCC could not find any violation of policy 

2. Progress

The RIPE NCC will provide a way to follow the progress of the investigation for both the person submitting a report and the organization(s) mentioned in the report.

This information will not be published publicly.

3. Transparency on reclaimed resources

The RIPE NCC already maintains a list of delegated resources, known as the 'stats' files or 'delegated' files.  In addition to these files the RIPE NCC will also maintain 'returned' files that lists:

• The type of resource
• The range of resources returned
• The date the resources have been returned to the RIPE NCC
• The date part or all of the resources have been re-allocated or re-assigned
• The reason for the return

As the 'delegated' files show the resources that the RIPE NCC has delegated to others, so will the 'returned' files show the resources delegated or returned to the RIPE NCC.  The format of the 'returned' files will be publicly published to facilitate automatic processing.

The reason for resources being returned can be:

• 'returned': Returned by the holder
• 'contact-lost': The RIPE NCC could not contact the holder
• 'policy-violation': Reclaimed because of a policy violation

The resource is marked as 'returned' when the holder voluntarily gives back resources to the RIPE NCC because they do not need those resources anymore or because a temporary assignment has ended.  Resources are marked as 'contact-lost' when the RIPE NCC cannot contact the holder of the resource, for example because the entity does not exist anymore, the contractual link with the holder, either directly or through a sponsoring LIR, is lost or the holder does not respond to inquiries or invoices.  The code 'policy-violation' is used for any kind of policy violation such as, but not limited to, contravening RIPE policies, incorrect registration in the RIPE Database, non-compliance with RIPE NCC audits, non-compliance with an arbiter ruling, falsified/incorrect information and fraudulent requests.

The content of the 'returned' file differs from the 'delegated' files in that it gives a historical overview and can therefore contain overlapping resource ranges.  For example: resources can be returned by the first holder, reallocated to a second holder and then be reclaimed again because of a policy violation by the second holder. Both the return events from the first and second holders are recorded in the 'returned' file. The re-allocation or re-assignment date field shows whether the resource has been reused after being returned to the RIPE NCC.

4. Attribution

This document is developed by the RIPE community.

The following people actively contributed by making proposals through the RIPE Policy Development Process:

Sander Steffann

Shane Kerr

Rationale

a. Arguments supporting the proposal

Currently complaints about shared public resources are not visible, and neither are the results of those complaints.  This can give the impression that the RIPE NCC is not actively handling such complaints.  To show the good stewardship of the RIPE NCC and to encourage people to assist the RIPE NCC by submitting accurate complaints we think that openness is required.

b. Arguments opposing the proposal

Such a policy as this forces a procedure on the RIPE NCC which is better left decided by the RIPE NCC. The proposers have tried to keep the policy as flexible as possible, while still providing transparency.