Yes, well worded and I agree with David's points.

If there are tools, mechanisms and also sanctions to be applied in a process that can be escalated those should be tried before taking more harsh changes due to a number of cases that may not justify it. I normally don't have problem and find it health to use the options available in a escalated manner before going to harder solutions.

Can we have some data about those who have received repeated marketing or sales material and which could be linked to the usage of Bulk Whois data or about cases that have been reported to APNIC and didn't progress as expected in regards to what is expected ?

Regards
Fernando

On 13/01/2025 14:38, David Farmer wrote:
I share Fernando's concerns in general.

However, I strongly object to the complete removal of postal contact information from Bulk Whois. This would significantly degrade the usefulness of this information for Internet Research purposes, one of the explicitly permitted uses of Bulk Whois. Withholding the street name and number could be reasonable for privacy protection; however, most postal contact information should remain in Bulk Whois for statistical correlation, including the city, state, province, county, and postal codes.

Furthermore, if you suspect abuse of Whois or Bulk Whois, this should be reported to APNIC;

APNIC's website states, "Any use of this material to target advertising or similar activities is explicitly forbidden and will be prosecuted. APNIC requests to be notified of any such activities or suspicions thereof."

If people violate APNIC policy, the first step is to report this to APNIC and ask APNIC to enforce its policies. Eliminating data from Whois or Bulk Whois is not the place to start. Now, if you are saying you have repeatedly reported such violations to APNIC, this policy change may be appropriate, but I don't see anything in the proposal that says any of the violations have been reported to APNIC.

Thanks.

On Mon, Jan 13, 2025 at 10:45 AM Fernando Frediani <[email protected]> wrote:

    Hi

    Although I do understand the motivations to this proposal, I
    normally don't like much this feel that may look obvious to many
    to remove as much as contact data in order to not be bothered with
    marketing and sales content due to the concern that make things
    more difficult for legitimate need to get in touch for
    troubleshooting and legal demands. If you are operating an
    Autonomous System and have responsibilities over it you must be
    able to be easily contacted in order to deal with the legitimate
    demands you commited when you became one, and for that there will
    be some burden which if reasonable should be accepted.

    I understand the proposal suggests removing it from the bulk
    access, but it has not been clear how it will work and how easy it
    will be for those with legitimate need to get these contact
    details, if it will be with not human interaction or if someone
    will need to fill a form and justify, etc ?

    Thanks
    Fernando

    On 13/01/2025 01:02, Bertrand Cherrier via SIG-policy wrote:
    Dear SIG members,

    A new proposal "prop-162-v001: WHOIS Privacy" has been sent to
    the Policy SIG for review.

    It will be presented at the Open Policy Meeting (OPM) at APNIC 59
    on Wednesday, 26 February 2025.

    https://conference.apnic.net/59/programme/programme/index.html#/day/8/

    We invite you to review and comment on the proposal on the
    mailing list before the OPM.

    The comment period on the mailing list before the OPM is an
    important part of the Policy Development Process (PDP). We
    encourage you to express your views on the proposal:

      - Do you support or oppose this proposal?
      - Does this proposal solve a problem you are experiencing? If so,
        tell the community about your situation.
      - Do you see any disadvantages in this proposal?
      - Is there anything in the proposal that is not clear?
      - What changes could be made to this proposal to make it more
    effective?

    Information about this proposal is appended below as well as
    available at:

    http://www.apnic.net/policy/proposals/prop-162

    Regards,
    Bertrand, Shaila, and Ching-Heng
    APNIC Policy SIG Chairs

    
-----------------------------------------------------------------------------------

    prop-162-v001: WHOIS Privacy

    
-----------------------------------------------------------------------------------

    Proposer:
    Jonathan Brewer ([email protected])


    1. Problem statement
    -------------------------
    Through permitted bulk access to APNIC whois, several
    organisations including Hurricane Electric and RecordedFuture
    republish physical addresses, email addresses, and telephone
    numbers of APNIC members.

    These details are freely available on the web and available for
    mass harvesting through the use of screen scraping technology. It
    is apparent that some third parties have used this data in a
    manner contrary to the APNIC whois data acceptable use agreement.

    In the past three years organisations including the Number
    Resource Society (Casablanca, Morocco), Unique IP Solutions
    (Faisalabad, Pakistan), Aileron IT (Wisconsin,  USA), and
    EarnheardData (details suppressed) have contacted my organisation
    via details published exclusively in APNIC whois. None of these
    contacts have been to do with a legitimate networking issue.

    2. Objective of policy change
    ----------------------------------
    This policy will eliminate the unnecessary publication of APNIC
    member organisation contact details. People with a legitimate
    need for these contact details can use a service directly
    provided by APNIC to obtain them.

    3. Situation in other regions
    --------------------------------
    Unknown

    4. Proposed policy solution
    --------------------------------
    APNIC should remove all email addresses, telephone numbers, and
    physical addresses from any bulk WHOIS data, and should cause any
    existing re-publishers of APNIC WHOIS data to remove this
    information from the Internet as a condition for continued access
    to data.

    5. Advantages / Disadvantages
    ------------------------------------
    Advantages:
    This should reduce future marketing calls to the NOC phone and
    marketing emails to the noc email address.

    Disadvantages:
    None. The information will still be available via
    APNIC-controlled WHOIS services which presumably are protected
    against illegitimate data harvesting.

    6. Impact on resource holders
    -----------------------------------
    No impact on resource holders.

    7. References
    ----------------

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