Agreed… Legal requirements always supersede any sort of non-statutory policy or contract in any case, so there is no need to open this can of worms in policy.
Owen > On Jul 27, 2023, at 07:31, Martin Hannigan <hanni...@gmail.com> wrote: > > Timely is open to interpretation by either party which means it could be > abused by either party. I would support an explicit requirement that is > measurable. Like 14 days. > > This is a can of worms which seems unnecessary: > “At the same time, privacy laws have been introduced in many jurisdictions > across ARIN’s service region which constrain registration in certain cases.” > Shouldn’t that be/already is dealt with in the RSA? > > Thanks, > > -M< > > > > From: ARIN-PPML <arin-ppml-boun...@arin.net> on behalf of Hunter, Kathleen > via ARIN-PPML <arin-ppml@arin.net> > Date: Thursday, July 27, 2023 at 9:06 AM > To: Peter Potvin <peter.pot...@accuristechnologies.ca>, David Farmer > <far...@umn.edu> > Cc: arin-ppml@arin.net <arin-ppml@arin.net> > Subject: Re: [arin-ppml] Draft Policy ARIN-2023-4: Modernization of > Registration Requirements > > The current timeframe on registrations works for myself, however, in the > event 7 days is changed to an extended period of time and not “timely”, I > think 14 days would be sufficient for anyone having issues registering large > amounts of data. “Where applicable by law” was discussed in the working group > as states like California now have CCPA. There are some business customers > which may be considered residential with a business IP account. The way the > text is today, all business customers /29 or more must be registered. This > would allow flexibility for those customers which fall into a gray area. The > language is in very early stages so at any point the shepherds can adjust the > text. As always, the AC appreciates your input. > > Kat Hunter > > From: ARIN-PPML <arin-ppml-boun...@arin.net> On Behalf Of Peter Potvin via > ARIN-PPML > Sent: Wednesday, July 26, 2023 10:08 PM > To: David Farmer <far...@umn.edu> > Cc: arin-ppml@arin.net > Subject: Re: [arin-ppml] Draft Policy ARIN-2023-4: Modernization of > Registration Requirements > > +1 on David's point. Unless "a timely manner" is defined somewhere within the > NRPM and a limit is provided, it's open to interpretation as the interpreting > party sees fit. > > In addition to this, I'm personally not a fan of adding the "to the extent > permitted and manner provided by applicable law" wording, because again: > which legislation is being applied here, from which jurisdiction and by which > party? This is also up to interpretation which without being defined may not > result in the intended actions or meaning. > > Regards, > Peter Potvin | Executive Director > ------------------------------------------------------------------------------ > Accuris Technologies Ltd. > > > > On Wed, Jul 26, 2023 at 9:37 PM David Farmer via ARIN-PPML > <arin-ppml@arin.net <mailto:arin-ppml@arin.net>> wrote: > I think the change from 7 days to timely, is unacceptable. Timely is simply > too vague and indefinite, it could mean virtually any timeframe, even up to > 90 days or 180 days. > > I’d be fine extending the timeframe to 14 days, or 10 business days, to allow > some flexibility for holidays. I’d even accept 21 days, but it needs to be a > definite timeframe. > > Thanks > > On Tue, Jul 25, 2023 at 11:11 ARIN <i...@arin.net <mailto:i...@arin.net>> > wrote: > On 20 July 2023, the ARIN Advisory Council (AC) accepted “ARIN-prop-322: > Modernization of Registration Requirements” as a Draft Policy. > > Draft Policy ARIN-2023-4 is below and can be found at: > > https://www.arin.net/participate/policy/drafts/2023_4/ > <https://urldefense.com/v3/__https:/www.arin.net/participate/policy/drafts/2023_4/__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQjOHTfdt$> > > You are encouraged to discuss all Draft Policies on PPML. The AC will > evaluate the discussion to assess the conformance of this draft policy with > ARIN's Principles of Internet number resource policy as stated in the Policy > Development Process (PDP). Specifically, these principles are: > > * Enabling Fair and Impartial Number Resource Administration > * Technically Sound > * Supported by the Community > > The PDP can be found at: > > https://www.arin.net/participate/policy/pdp/ > <https://urldefense.com/v3/__https:/www.arin.net/participate/policy/pdp/__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQlDHuvwM$> > > Draft Policies and Proposals under discussion can be found at: > > https://www.arin.net/participate/policy/drafts/ > <https://urldefense.com/v3/__https:/www.arin.net/participate/policy/drafts/__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQjzoBBst$> > > Regards, > > Eddie Diego > Policy Analyst > American Registry for Internet Numbers (ARIN) > > > Draft Policy ARIN-2023-4: Modernization of Registration Requirements > > Problem Statement: > > Registration is central to the value provided by ARIN to the > community. Registry quality depends greatly upon the timely > registration of reassignments from ISPs to end users. The motivation > for registration has waned since the depletion of the free pool. At > the same time, privacy laws have been introduced in many jurisdictions > across ARIN’s service region which constrain registration in certain > cases. This combination of forces has generally discouraged many ISPs > from registering reassignments. Registration remains vital to a number > of stakeholders, including law enforcement and network operators. > > This proposal aims to modernize the registration-related policies in > Section 4 by introducing language that is meant to make registration > requirements more adaptable to changing privacy laws, while reminding > ISPs of the importance of registration when feasible for the benefit > of the community. > > Policy Statement: > > In section 4.2.3.7.1, > Replace > "Each IPv4 reassignment or reallocation containing a /29 or more > addresses shall be registered via SWIP or a directory services system > which meets the standards set forth in section 3.2." > With > "Each IPv4 reassignment or reallocation containing a /29 or more > addresses shall be registered in the WHOIS directory via SWIP or a > directory services system which meets the standards set forth in > section 3.2, in a timely manner, to the extent permitted and manner > provided by applicable law." > > Retire section 4.2.3.7.2 Reassignments and Reallocations Visible > Within Seven Days > > Rename 6.5.5.1 > From > "Reassignment Information" > To > "Reassignment and Reallocation Information" > > In section 6.5.5.1, > Replace > "Each static IPv6 reassignment or reallocation containing a /47 or > more addresses, or subdelegation of any size that will be individually > announced, shall be registered in the WHOIS directory via SWIP or a > distributed service which meets the standards set forth in section > 3.2. Reassignment and reallocation registrations shall include each > client’s organizational information, except where specifically > exempted by this policy." > With > "Each static IPv6 reassignment or reallocation containing a /47 or > more addresses, or subdelegation of any size that will be individually > announced, shall be registered in the WHOIS directory via SWIP or a > distributed service which meets the standards set forth in section > 3.2, in a timely manner, to the extent permitted and manner provided > by applicable law. Reassignment and reallocation registrations shall > include each client’s organizational information, except where > specifically exempted by this policy." > > Retire section 6.5.5.2 Reassignments and Reallocations Visible Within Seven > Days > > Timetable for Implementation: Immediate > > > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net > <mailto:ARIN-PPML@arin.net>). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > <https://urldefense.com/v3/__https:/lists.arin.net/mailman/listinfo/arin-ppml__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQgExMfmN$> > Please contact i...@arin.net <mailto:i...@arin.net> if you experience any > issues. > -- > =============================================== > David Farmer Email:far...@umn.edu > <mailto:email%3afar...@umn.edu> > Networking & Telecommunication Services > Office of Information Technology > University of Minnesota > 2218 University Ave SE Phone: 612-626-0815 > Minneapolis, MN 55414-3029 Cell: 612-812-9952 > =============================================== > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net > <mailto:ARIN-PPML@arin.net>). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > <https://urldefense.com/v3/__https:/lists.arin.net/mailman/listinfo/arin-ppml__;!!CQl3mcHX2A!CNMWCMCN350m3SFzf0lyRHiwCE0y6q9kLTUTjjxubQCCWlSppgbe0JzYlNG2AUHLgpoujj5KHGoTZQVx6uBeQgExMfmN$> > Please contact i...@arin.net <mailto:i...@arin.net> if you experience any > issues. > _______________________________________________ > ARIN-PPML > You are receiving this message because you are subscribed to > the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). > Unsubscribe or manage your mailing list subscription at: > https://lists.arin.net/mailman/listinfo/arin-ppml > Please contact i...@arin.net if you experience any issues.
_______________________________________________ ARIN-PPML You are receiving this message because you are subscribed to the ARIN Public Policy Mailing List (ARIN-PPML@arin.net). Unsubscribe or manage your mailing list subscription at: https://lists.arin.net/mailman/listinfo/arin-ppml Please contact i...@arin.net if you experience any issues.
