[db-wg] Fwd: proposal: new attribute 'geofeed:
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Carlos Friaças
cfriacas at fccn.pt
Wed Jan 27 20:37:59 CET 2021
Hi, (just my two cents) At the GDPR trainings/sessions i have been a part of, there is the "purpose" bit in GDPR. One natural person can choose to publish (its own) personal data if there is a purpose for it. In the RIPEdb case, the purpose seems obvious: to provide a worldwide reachable contact for a given resource. Also, if someone uses the same phone# for personal *and* business purposes, the choice to use that phone# or to find another exclusively business-oriented phone# should be that someone's choice... Regards, Carlos On Wed, 27 Jan 2021, denis walker via db-wg wrote: > HI Maria > > Thanks for the preliminary analysis. I do have a couple of questions below... > > On Wed, 27 Jan 2021 at 09:21, Maria Stafyla <mstafyla at ripe.net> wrote: >> >> Hi Denis, all, >> >> Thank you for your patience in this matter. >> >> We looked into this and the answer varies depending on the situation. >> >> Allocations and assignments can be made to either natural or legal persons. In the inetnums and inet6nums to be created the contact details of the relevant person will be inserted. >> >> For example, if a /27 IPv4 block is assigned to a legal person, the geofeed data will likely not constitute personal data. This will not be the case if an IPv4 /32 (single IP address) is assigned to a sole trader and the assignment is registered under the sole trader's name in the RIPE Database*. In this latter example, the inetnum will contain the contact details of the sole trader and the geofeed data will qualify as personal data. >> >> This is because personal data under GDPR is defined as any information that relates to an identified or identifiable natural person. >> > > So in this situation, if this sole trader has a phone used exclusively > for the business and a business email address and these are listed as > their business contact details, are you saying the business phone and > email are still classed as personal data? If that is true then > anything 'relating' to the business is also 'relating' to the natural > person and is therefore personal data. > > cheers > denis > co-chair DB-WG > > >> Based on the above and before introducing the geofeed attribute, a full impact analysis of its implementation would have to be conducted by the RIPE NCC. >> >> If you have any questions, please let us know. >> >> Kind regards, >> >> Maria Stafyla >> Senior Legal Counsel >> RIPE NCC >> >> >> * Please note that the relevant RIPE Policy (https://www.ripe.net/publications/docs/ripe-733#62) is allowing not to register assignments on the end user's contact details but as part of the service provider's internal infrastructure. >> >> >> On 08/01/2021 11:27, Maria Stafyla wrote: >> >> Hi Denis, all >> >> Please allow us some time to look into this and we will get back to you >> with our feedback next week. >> >> Kind regards, >> >> Maria Stafyla >> Senior Legal Counsel >> RIPE NCC >> >> >> ---------- Forwarded message --------- >> From: denis walker <ripedenis at gmail.com> >> Date: Thu, 7 Jan 2021 at 15:59 >> Subject: Re: [db-wg] Fwd: proposal: new attribute 'geofeed: >> To: Hank Nussbacher <hank at interall.co.il>, <legal at ripe.net> >> Cc: Database WG <db-wg at ripe.net> >> >> >> HI Hank, colleagues >> >> Whilst I can't answer your basic question, I could say that if the >> IETF approves a change to RPSL, with the RIPE Database data model >> based on RPSL, in principle we should implement the RPSL change. >> >> Perhaps another question, to the RIPE NCC legal team, if I have a >> fixed IP address or block of addresses, is this geofeed location data >> personal data under the terms of GDPR? >> >> cheers >> denis >> co-chair DB-WG >> >> On Wed, 6 Jan 2021 at 07:01, hank--- via db-wg <db-wg at ripe.net> wrote: >> >> I guess I am not understanding something. >> Why do we need a geofeed attribute? What problem are we trying to solve? >> >> I understand why each block of IPs needs to be associated with a >> country, so that certain language specific auto-customizations will >> work. But what purpose is there to know that a /24 is in central >> Amsterdam? Is the purpose to assist marketers in geo-targetted sales? >> Is the purpose for network engineering (not sure what major problem >> we have that needs this)? >> >> Is the purpose to know where you are so that in the event of an >> emergency (terror, tornado, etc) you can get emergency targeted >> alerts? If so, then the geofeed has to be at the /32 level and since >> many if not most IPs are mobile, and that is where you will get the >> alert from - from your cellphone provider, I still don't quite >> understand the reason for a geofeed tag. >> >> Can someone clue me in? >> >> Thanks, >> Hank >> >> Caveat: The views expressed above are solely my own and do not express >> the views or opinions of my employer >> >> >
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