Hi, I’m out of office till 22 August. Any RIPE Labs related queries can be sent to l...@ripe.net and one of my colleagues will get back to you.
Cheers, Alun On 28 Jul 2022, at 16:58, Laurent Pellegrino via db-wg <db-wg@ripe.net> wrote: > Hi there, > > Following others, this looks like a crazy situation. Reading the discussions > for a long time it looks like you are turning around since months with > contradictory actions and no clear convergence on the defined purposes. > Nothing personal but just my opinion reading your discussions regularly. > > I understand geofeeds may contain personal data but you manage the pointer > not the content as others said. Personal information from geofeeds is not > collected nor processed. > > Citing the answer from Maria "other geolocation information is already > provided in the RIPE Database (i.e. geoloc, country code attributes in ORG > and resource objects)", I am even more confused: > • How can you guarantee a geoloc (latitude, longitude) is not > personal information in that case? Following the recent discussions about the > proposal to hide street addresses from the registry, this looks weird. A > geoloc is entered by a user with no validation and nothing prevents people > from putting coordinates to a location that identifies a real address > (outside of this discussion, it's crazy to see geolocs pointing in the ocean, > or maybe many subnets are in use on oil rigs...). > > > • Is there really a consensus about what the country code in > "resource objects" other than organizations mean? > Citing your docs for > inetnum object: "It has never been specified what this country represents. It > could be the location of the head office of a multi-national company or where > the server centre is based or the home of the End User. Therefore, it cannot > be used in any reliable way to map IP addresses to countries.". Can we really > consider this as geolocation information? > > It's sad to see real solutions around geolocation (which helps users in many > ways) overthought and killed in the eggs. > > Kind regards, > Laurent Pellegrino > > On Thu, Jul 28, 2022 at 3:57 PM Gert Doering via db-wg <db-wg@ripe.net> wrote: > Hi, > > On Thu, Jul 28, 2022 at 01:33:07PM +0200, Maria Stafyla via db-wg wrote: > > As mentioned in the Legal Review Impact Analysis, if the geofeed > > attribute is inserted for registrations of assignments that are > > reasonably assumed to be related to one individual user, then the > > attribute will be considered as containing personal data and GDPR will > > apply. This is why we have proposed to implement restrictions. > > I maintain that this part of the analysis is fundamentally flawed. > > The size of an assignment does not have any correlation to the entity > that the prefix is assigned to - we can assign IPv4 /32s to corporate > customers, and we can assign IPv4 /28s to private end users, and this > is perfectly within the scope of the relevant RIPE policies. > > Inventing restrictions based on "but it looks like!!" guesswork is > not what we are paying the RIPE NCC for. > > *Especially* as the information entered is not PII itself, but > a pointer to a URL which could, as has been stated, contain anything > from "ZZ" to very detailed addresses, fully under control and fully > in the responsibility of the entity maintaining that list. > > > I have the nagging suspicion that people are not listening here, because > all this was already said months ago, and we're still running in circles. > > Gert Doering > -- totally not interested in geofeed:, but annoyed by arbitrary > restrictions not in line with RIPE policies > -- > have you enabled IPv6 on something today...? > > SpaceNet AG Vorstand: Sebastian v. Bomhard, Michael Emmer > Joseph-Dollinger-Bogen 14 Aufsichtsratsvors.: A. Grundner-Culemann > D-80807 Muenchen HRB: 136055 (AG Muenchen) > Tel: +49 (0)89/32356-444 USt-IdNr.: DE813185279 > -- > > To unsubscribe from this mailing list, get a password reminder, or change > your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/db-wg > -- > > To unsubscribe from this mailing list, get a password reminder, or change > your subscription options, please visit: > https://lists.ripe.net/mailman/listinfo/db-wg
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