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 22 Aug 2022, at 07:53, Alun Davies via db-wg <db-wg@ripe.net> wrote: > 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 22 Aug 2022, at 07:52, Alun Davies via db-wg <db-wg@ripe.net> wrote: > > 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 22 Aug 2022, at 07:47, Alun Davies via db-wg <db-wg@ripe.net> wrote: > > 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 29 Jul 2022, at 17:31, denis walker via db-wg <db-wg@ripe.net> wrote: > > Hi Maria > > There has been quite a discussion in the last 24 hours from various angles > about interpretation of terminology and purposes and context. Perhaps this is > a good moment to pause and allow the legal team to review the discussion and > see if anything that has been said affects your analysis. > > Cheers > denis > Co-chair DB-WG > > > On Thu, 28 Jul 2022, 13:33 Maria Stafyla via db-wg, <db-wg@ripe.net> wrote: > > Dear colleagues, > Following the legal update we provided on NWI-13: Geofeed at the DB WG > session at RIPE 84, here is our analysis in case further discussion on this > topic is needed. > > > Executive Summary: > - The RIPE Database is meant to contain specific information for its > documented purposes. > - Information inserted in the geofeed attribute could in some cases > qualify as personal data. > - The current purposes could explain geolocation information to be > inserted only for ‘scientific research into network operations and topology’. > - This purpose does not justify the processing of personal data; > therefore restrictions had to be put in place to avoid the processing of > unnecessary personal data. > - The restrictions are now implemented based on the status of the > registration. > - If the purposes of the RIPE Database have changed in the meantime, > this should be established via the community processes and documented. In > that case we will re-evaluate the situation and the need for restrictions. > Until then, the restrictions remain necessary. > > Legal Analysis: > The RIPE Database is meant to contain specific information for the purposes > that are defined in the RIPE Database Terms and Conditions. > In terms of the _personal data_ inserted in there, the purpose that justifies > its publication is to facilitate the coordination of network operations for > the smooth and uninterrupted operation of Internet; this purpose explains why > contact details of resource holders or their appointed contact persons are > required. > Before any new type of personal data is permitted to be inserted in the RIPE > Database, we must evaluate if their processing is required for the purposes > already defined and their processing can be considered in line with the basic > personal data processing principles. > Although it is the responsibility of the party inserting personal data to > ensure that they have the appropriate legal grounds before doing so, the RIPE > NCC has also shared responsibilities with regards to the personal data in the > RIPE Database. This is because the RIPE NCC is the party that is making the > RIPE Database available and implements the instructions given by the RIPE > community. > 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. > These restrictions are essential to avoid any processing of personal data > that is not required or necessary for the currently defined purposes of the > RIPE Database and to limit the RIPE NCC's liability as a party with shared > responsibilities in relation to the personal data inserted in the RIPE > Database. > Regarding the _(non-personal) data _inserted in the RIPE Database, it is also > paramount that only data that is needed for the defined purposes of the RIPE > Database is inserted. > According to the RIPE Database Terms and Conditions, introducing the geofeed > attribute (with restrictions) would be considered in line and acceptable to > be used only for scientific research into network operations and topology > (see Art. 3). > We also understand that the purposes the RIPE Database must fulfil are not > static but evolve over time. > The RIPE Database Requirements Task Force has recently concluded its work > and, with regard to geolocation, it has established that, although there is > an active user group for geolocation data, geolocation itself is not an > objective that the RIPE Database should fulfil. > If the community's interests have changed since then and it is now agreed > that geolocation is one of the purposes the RIPE Database must fulfil, this > should be decided via the community's processes and reflected in the RIPE > Database Terms and Conditions. > In line with the data management principles proposed by the RIPE Database > Requirements Task Force, it would be prudent to approach this issue > holistically, taking into account that other geolocation information is > already provided in the RIPE Database (i.e. geoloc, country code attributes > in ORG and resource objects). > On the basis of a new purpose for the geolocation information, we could then > reassess the situation to understand whether the restrictions on the geofeed > attribute are still necessary or whether it is justified to process personal > data for this purpose. > Kind regards, > > Maria Stafyla > Senior Legal Counsel > RIPE NCC > > -- > > 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 > -- > > 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 > -- > > 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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