Hello Christopher,
This is Koki from JPOPF attendee.
v002 change word " Bulk WHOIS" to "public access WHOIS".
I think this mean to affect to all whois data from this policy change,
Proposal show that you can access contact data from My APNIC or authenticated
API.
If Other RIRs memeber or NIR member and stakeholder who not contracted with
APNIC
need to use authenticated API.
This way, Some stakeholder feel hard to say "public open access" , I think.
If not to change can not access by https://whois.apnic.net, thats good.
If misunderstanding, please correct me.
Sincerely Regards,
Koki Nakagawa
On 2025/02/19 9:53, Christopher Hawker wrote:
Hello Satoru,
[Speaking for myself and based on my own observations, and not that of the
proposal author.]
I believe there has been a fundamental misunderstanding of the proposal. The proposal
does not discuss the complete removal of all contact information from the Whois
system, rather *it only discusses the removal of contact information from bulk Whois
data*. People will still be able to go to https://whois.apnic.net
<https://whois.apnic.net> and lookup contact information for INRs where
required, if there's a need to contact the network operator. Therefore, the examples
you've provided will still be able to access the contact information that they may
require, they just won't be able to download it in bulk. I agree with this, as the
primary purpose for contact information is for network operators to be able to
contact each other should there be a need. There's no technical requirement for bulk
data to contain contact information.
If there's a legitimate business case for bulk contact info I'm happy to hear
about it.
Regards,
Christopher Hawker
------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
*From:* Tsurumaki, Satoru <[email protected]>
*Sent:* Wednesday, February 19, 2025 11:09 AM
*To:* [email protected] <[email protected]>
*Subject:* [sig-policy] Re: New version : prop-162: WHOIS Privacy v002
Dear Colleagues,
I am Satoru Tsurumaki from the Japan Open Policy Forum Steering Team.
On February 12, we held a meeting to discuss prop-162. Based on this
discussion, I would like to share key feedback from our community.
While this feedback is sent on my behalf, it summarizes the opinions
of the 14 Japanese community members who attended the meeting.
Many participants expressed serious concerns and strong opposition to
removing contact information from public whois access.
There is an opinion that the discussion of which information to
disclose to the user with what qualification have long been done in
ICANN for gTLD policy hence it may need a substantial community-wide
discussion to carefully design that.
(comment details)
- There is a major concern that whois will no longer serve its
original purpose of helping internet operations by providing contact
information.
- Police, lawyers, and other professionals use whois for criminal
investigations and other purposes. However, it is unrealistic to
expect all such organizations worldwide to sign individual contracts
to access this information.
- The removal of contact information from whois should be discussed
with all potentially affected stakeholders.
Regards,
Satoru Tsurumaki
JPOPF Steeling Team
2025年2月10日(月) 9:17 Bertrand Cherrier via SIG-policy
<[email protected]>:
Dear SIG members,
A new version of the proposal "prop-162: 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/
<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
<http://www.apnic.net/policy/proposals/prop-162>
Regards,
Bertrand, Shaila, and Ching-Heng
APNIC Policy SIG Chairs
-----------------------------------------------------------------------------------
prop-162-v002: WHOIS Privacy
-----------------------------------------------------------------------------------
Proposer:
Jonathan Brewer ([email protected])
1. Problem statement
-------------------------
More than 400 organisations around the world have bulk access to APNIC's
WHOIS data and may download the complete data set as required.
Cybersecurity companies, ISPs, universities, researchers, and law
enforcement agencies are amongst those with access.
Several organisations including Hurricane Electric and RecordedFuture
republish this data as part of their applications and online systems,
including physical addresses, email addresses, and telephone numbers of
APNIC members.
These contact 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), Cogent Communications
(Washington DC, USA) and EarnheardData (details suppressed) have
contacted APNIC members via details published exclusively in APNIC
WHOIS. None of these contacts have been to do with legitimate networking
issues.
2. Objective of policy change
----------------------------------
This policy will eliminate the unnecessary distribution and retention of
APNIC member organisation contact information by third parties. APNIC
systems will become the only source of obtaining address, phone, fax-no,
e-mail, and notify data for APNIC members.
This policy change will not prevent APNIC members or other authorised
users of APNIC WHOIS from obtaining contact information for network
resources in either ad-hoc or automated queries.
3. Situation in other regions
--------------------------------
I have not found evidence that other RIRs limit access to contact
details. Multiple ccTLDs have implemented WHOIS privacy for domain
names, including Australia [1] and Germany [2].
4. Proposed policy solution
--------------------------------
APNIC should remove address, phone, fax-no, e-mail, and notify fields
(the Contact Information) from Org, IRT, abuse-c and role objects from
public access WHOIS.
Responses to unauthenticated API queries should no longer display the
Contact Information.
The Contact Information should be removed from the dataset distributed
to bulk consumers.
APNIC should cause any existing bulk users of APNIC WHOIS data to remove
the Contact Information from their own systems and from the Internet.
MyAPNIC and authenticated API access should be the only way of obtaining
the Contact Information of APNIC users.
APNIC should publish a list of all authenticated API users with access
to the Contact Information. APNIC should publish statistics on requests
for the Contact Information by requestor.
5. Advantages / Disadvantages
------------------------------------
Advantages:
This should enhance privacy and data sovereignty, while reducing
nuisance contacts.
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
----------------
[1]
https://www.domainregistration.com.au/infocentre/info-private-registration.php
<https://www.domainregistration.com.au/infocentre/info-private-registration.php>
[2]
https://www.denic.de/en/whats-new/press-releases/article/extensive-innovations-planned-for-denic-whois-domain-query-proactive-approach-for-data-economy-and/
<https://www.denic.de/en/whats-new/press-releases/article/extensive-innovations-planned-for-denic-whois-domain-query-proactive-approach-for-data-economy-and/>
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--
--
Satoru Tsurumaki
BBIX, Inc
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