[ncc-services-wg] Publication of Legal Address of Internet Number Resource Holders

Hello.

Before lunch, I actually read the text of this proposal, so I'm no
longer just reacting to other postings on the list.

Leaving aside questions of data protection and due process, here's my tuppence-worth.

- The summary of the proposal is (curiously) rather longer than the proposal itself.
- The summary suggests that the proposed policy, if adopted, would not be mandatory; however, this idea is not reflected in the policy text. The reader is left to wonder what is actually intended.
- As far as I can see, the claim that _"This proposal fixes an issue ..."_ is made without reference to either a use case or a problem statement. Other claims such as, _"This proposal is essential ..."_ or _"This is a chance ..."_ are likewise made without elaborating their respective basis.
- The idea that _"The RIPE NCC will publish ..."_ seems to be based on a misconception about the operation of the public RIPE Whois database and the rôle of the RIPE NCC.  The NCC provides a platform where the **authorized maintainer** of a particular database object can add, modify, or delete any attribute of the object.  For the **NCC to propagate information** which it holds for other purposes into a database object (for which it is not the authorized maintainer) would be a **violation of a boundary of authority**.  I am sure that neither would the NCC countenance such action nor the community accept it.
- The mail archives of both the RIPE **Database** and **Anti-Abuse** working groups provide ample evidence of the challenges involved both in maintaining accurate data and in agreeing what the data means and how it should be used.
- In discussion on this mailing list, but not in the proposal itself, it seems to be expected by some that the proposal, if adopted and implemented, would facilitate timely action by LEAs in pursuing their investigations and in securing material of interest.  **I cannot but consider that reliance on a new, non-mandatory database attribute**, whose accuracy will likely be no better than that of any existing attribute, whose maintenance will depend on the availability and freedom from conflicting demands of the respective authorized maintainer, which is likely to be misleading if this maintainer is a malefactor of interest, and which can provide only formal (rather than material) evidence, **will delay, rather than advance the work** of an LEA.


Best regards,
Niall O'Reilly



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