[anti-abuse-wg] Privacy requirements
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Shane Kerr
shane at time-travellers.org
Thu Dec 29 14:20:34 CET 2011
Florian, On Wednesday, 2011-12-28 14:40:02 +0000, Florian Weimer <fweimer at bfk.de> wrote: > >> Just make it opt-in, so that people can decide whether they want > >> to publish their abuse contact point or not. > > > > I thought is already is "opt-in" as the contact enters the > > information with the knowledge it will be published. > > > > If it is opt-in the EU data protection laws do not come into play > > since there is an exemption for those > > that opt-in to their info being published. > > I was surprised when this was announced and I believe RIPE NCC's legal > counsel was and is wrong. It would have been better to advise its > members that they need to make sure that they have consent from the > folks whose data they've submitted to the RIPE NCC for publication. > This is what DENIC did when it was discovered that the WHOIS for > 9.4.e164.arpa, despite being nominally opt-in, was populated by > default with personally identifiable information by several DENIC > members. Perhaps it makes sense to create an explicitly privacy-free form of contact information in the database? While we could re-use the ROLE object type for this, maybe we should be explicit, and make a NON-PERSON-CONTACT-INFORMATION-THAT-THE-WHOLE-INTERNET-CAN-READ object type? ;) -- Shane
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