[address-policy-wg] IP Addressing policy on personal contact info (kf)

There are two things with regards the informations recorded in the data
base. I am certainly glad that you talked with the Dutch Data Protection
Authority but as fas as I know it is the laws and regulations of the country
concerned which matters.  Sure you could say that the RIPE DB is located in
the Caymen Island but if we are a European Institution and if this
Institution wants to be respected by the different EU countries, it has to
follows the rules of the different countries.

I can't talk about what rules are in other countries because I don't know
them enough but in France you have to have done a proper declaration to a
French body (CNIL) which takes care of this and you must have the
authorisation from the people whose information is recorded.  Other
countries probably have other rules. I don't know if the RIPE DB has done
the needed paper work with the French CNIL but if not, then NOT one French
LIR should record information in the DB.  The risk is heavy fine and jail.

This is just an an example but with the EU Rules being somewhat different in
each country this subject of privacy should be seriously reviewed and the
right lawyer put onto it.  This is not just privacy but even just recording
information in a DB about the LIR's subscribers is forbidden in France
unless properly declared through the body CNIL.


As far as spam is concerned:  spammers are using the e mail addresses
recorded in the data base.  I receive spams daily on the addresses (role
addresses for that matter) which have been entered in the data base.    THe
RIPE DB is one of the best source to obtain mailing list:  it has the name
of the LIR and roles which in turns redistribute to internal mailing lists
of the LIR or of subscribers of the LIR.

I don't have solutions to the above points but these are important topics
which could be discussed in the next Ripe meeting.

I have seen the efforts to clean the DB.  There are plenty of positive
things but as far as I know the privacy and just recording personal infos in
the DB could use a little review.

Pascal Julienne
President Directeur General
EURO CONNECT SA
130, rue du Bourg-Bele - BP 21099 - 72001 LE MANS Cedex 1 - FRANCE

Tel : (33) 02 43 14 12 76 - Fax : (33) 02 43 14 12 77
http://www.euroconnect.fr

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-----Message d'origine-----
De : address-policy-wg-admin at ripe.net
[mailto:address-policy-wg-admin at ripe.net]De la part de Shane Kerr
Envoye : jeudi 14 aout 2003 18:04
A : Pascal Julienne
Cc : address-policy-wg at ripe.net; db-wg at ripe.net
Objet : Re: [address-policy-wg] IP Addressing policy on personal contact
info (kf)


Pascale Julienne,

Pascal Julienne wrote:
> In France there is such a thing as unlisted phone numbers which
> remain private and unknown.  Further, the RIPE DB is becoming the
> best spam list in the world.  So yes, responsability lays with LIR,
> yes let's clean the DB, yes respect privacy.

I think there are two sides to this issue.


One is what the RIPE NCC can and has done to increase the privacy of
people who have contact information in the Database.  We have been
trying to increase the privacy protections in the Database over time:

- person/role objects removed from public FTP site
- DB automatically rate limits access to person/role objects
- mntner/irt objects removed from public FTP site
- .DE person object deletion
- automatic cleanup of unreferenced person/role objects

The Allocation Editor on the LIR Portal should allow LIRs to keep
their contact data up-to-date.

We have talked with the Dutch Data Protection Authority about the
Database as well, to make sure that we don't run afoul of the EU
privacy directives.

There has been some discussion at the last RIPE meeting about how the
Database both aids and hinders spammers.  Suggestions such as checking
validity of contact information, as well as possibly putting fake
entries in the Database and tracking spam they receive were mentioned.


The second issue is deciding on what contact data *should* be in the
Database.  This is the job of the address-policy-wg, and perhaps the
db-wg.  A related issue is how the data should be accessed, which is
also something that can be decided by the same groups.  Katri Forsberg
  did a service by raising the issue.


As a final issue, I am curious why you say the RIPE Database is
becoming the best spam list in the world!  I think that it probably
generates a lot of spam for LIRs, because they have their contact
information on many objects in the Database.  I don't know any way to
avoid this if the Database is public.

I hope that for the end users who's information is in the Database for
only a small number of addresses that they do not get much spam
originating from the publication in the Database.  The RIPE NCC is
certainly interested in mechanisms that we can set up to prevent such
use, as it is explicitly *not* allowed by the license that we provide
for the Database.

--
Shane Kerr
RIPE NCC