Dear SIG members,

Here is the Secretariat impact assessment for proposal “prop-162-v001: WHOIS 
Privacy” and the same is also published at:

    https://www.apnic.net/community/policy/proposals/prop-162/

The Secretariat notes that this proposal suggests removing member organization 
contact details (email, telephone numbers, and physical addresses) from the 
bulk WHOIS data, and the existing re-publishers of APNIC Whois data must remove 
contact information as a condition for continued access to data.

Questions/Comments:

  *   To date, the Secretariat has not received any reports of Whois data abuse 
relating to organizations that have signed the AUP to access bulk data. 
According to our records, Hurricane Electric and RecordedFuture do not have 
access to APNIC bulk Whois data.
  *   Over 400 organizations now have access to bulk Whois data. Around 70 
unique logins have accessed bulk Whois data over the last 3 months.
  *   The current Whois data acceptable use agreement (AUA) does not 
contemplate the revocation of access by the Secretariat. However, the 
Secretariat can implement stronger terms and require accession to them for 
continued access to the bulk Whois data. This would not address prior issues 
but may help limit the impact going forward.
  *   The existing AUA does not contemplate a requirement to delete prior data 
without evidence of misuse. As noted above with respect to access, APNIC can 
remove ongoing access until such time as the re-publisher accedes to new terms.

Implementation:

This proposal may require changes to APNIC systems, internal policy, 
procedures, and agreements. If this proposal reaches consensus, implementation 
may be completed within three (3) months.

Regards,
Sunny
APNIC Secretariat


On 13/01/2025 2:02 pm, 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]<mailto:[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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