Alternative solution for a problem created by implementing the proposed
proposal. What's the merit then for such a proposal?

Regards
________________________________________________________
Anupam Agrawal | India Internet Foundation - Chair | 91 905 170 3611


On Thu, Feb 20, 2025 at 7:06 AM Vivek Nigam <[email protected]> wrote:

> Hi Liam,
>
>
>
> We offer a Registry API service that supports single-object retrieval and
> updates. However, this service is currently available exclusively to APNIC
> Members. We would need to develop an alternative solution for others.
>
>
>
> Thanks
>
> Vivek
>
>
>
> *From: *Stephens, Liam <[email protected]>
> *Date: *Wednesday, 19 February 2025 at 9:39 pm
> *To: *Vivek Nigam <[email protected]>, Christopher Hawker <
> [email protected]>, Tsurumaki, Satoru <[email protected]>,
> [email protected] <[email protected]>, Jonathan Brewer <
> [email protected]>
> *Subject: *RE: [sig-policy] Re: New version : prop-162: WHOIS Privacy v002
>
> Thanks Vivek,
>
>
>
> On reading v002 of the policy it seems that the scope has broadened from
> the 400 users of the **bulk** Whois service to include all queries using
> unauthenticated access to whois.apnic.net from a Whois client.
>
>
>
> @Jonathan Brewer <[email protected]>, can you please confirm if this is
> the case?
>
>
>
> If you are now including unauthenticated access in your scope, this could
> have significant impact on providers who use the Contact Information
> (primarily email address) in automated approval systems of customer routing
> requests. Implementation of this policy will require these providers to
> migrate to an authenticated access method, which could take more than three
> months to establish. Many more months in some cases, such as large ISP’s
> where the wheels turn ever-so-slightly slower! Significant resources may
> also be required.
>
>
>
> Are you (or APNIC/@Vivek Nigam <[email protected]>) able to provide more
> information about the authenticated access request process (if it exists),
> such as how it is requested, will an AUP apply, can larger entities request
> access for multiple users and are there limits, whether source IP’s need to
> be whitelisted, details on how it is used, etc.
>
>
>
> Thanks.
>
> Regards,
>
> Liam
>
>
>
>
>
>
>
> General
>
> *From:* Vivek Nigam <[email protected]>
> *Sent:* Wednesday, 19 February 2025 2:39 PM
> *To:* Stephens, Liam <[email protected]>; Christopher
> Hawker <[email protected]>; Tsurumaki, Satoru <[email protected]>;
> [email protected]
> *Subject:* Re: [sig-policy] Re: New version : prop-162: WHOIS Privacy v002
>
>
>
> Hi Liam,
>
>
>
> We will contact these entities to inform them of the proposal and request
> their input on any potential impacts it may have.
>
>
>
> Thanks
>
> Vivek
>
>
>
> *From: *Stephens, Liam via SIG-policy <[email protected]>
> *Date: *Wednesday, 19 February 2025 at 11:28 am
> *To: *Christopher Hawker <[email protected]>, Tsurumaki, Satoru <
> [email protected]>, [email protected] <[email protected]
> >
> *Subject: *[sig-policy] Re: New version : prop-162: WHOIS Privacy v002
>
> Hi All,
>
>
>
> I agree with Chris’s statement about a fundamental misunderstanding, and I
> believe it may be due to the lack of awareness of the **bulk** Whois
> service offered by APNIC. This bulk service offering is an option (akin to
> being given a hardcopy of a Whitepages telephone directory), whereby the
> user has the entire Whois database in their possession. This bulk Whois
> offering is separate to the Whois query services that, I imagine, most of
> us use, namely whois.apnic.net (via a Whois client) and the web version
> at https://whois.apnic.net.
>
>
>
> Would it be worthwhile adding more clarity on the existing Whois
> offerings, and which ones are impacted, into the proposal?
>
>
>
> I do agree with Satoru-san that some law enforcement agencies may be
> impacted by the change, as they may use the bulk data in their own systems
> for their non-networking teams to consume. It would be great if APNIC, as
> the provider of the service, could contact the 400 entities to advise them
> that changes may be coming, and confirm whether it would impact them.
>
>
>
> Regards,
>
> Liam Stephens
>
>
>
>
>
> General
>
> *From:* Christopher Hawker <[email protected]>
> *Sent:* Wednesday, 19 February 2025 11:53 AM
> *To:* Tsurumaki, Satoru <[email protected]>; [email protected]
> *Subject:* [sig-policy] Re: New version : prop-162: WHOIS Privacy v002
>
>
>
> [External Email] This email was sent from outside the organisation – be
> cautious, particularly with links and attachments.
>
> 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 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/
> >
> > 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-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://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.domainregistration.com.au%2Finfocentre%2Finfo-private-registration.php&data=05%7C02%7C%7C4405fe8aec3d4491f1cb08dd50da0c39%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C638755619640274688%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=vSrEJUhG2%2FPzMpXRAGAMP9Ud%2Bb6cjsHz5SfjWeyflCs%3D&reserved=0>
> > [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://aus01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.denic.de%2Fen%2Fwhats-new%2Fpress-releases%2Farticle%2Fextensive-innovations-planned-for-denic-whois-domain-query-proactive-approach-for-data-economy-and%2F&data=05%7C02%7C%7C4405fe8aec3d4491f1cb08dd50da0c39%7C127d8d0d7ccf473dab096e44ad752ded%7C0%7C0%7C638755619640292214%7CUnknown%7CTWFpbGZsb3d8eyJFbXB0eU1hcGkiOnRydWUsIlYiOiIwLjAuMDAwMCIsIlAiOiJXaW4zMiIsIkFOIjoiTWFpbCIsIldUIjoyfQ%3D%3D%7C0%7C%7C%7C&sdata=XLW2nNvn8%2BwiWT%2Fp1CaB1vEvAGs7niNr8SGCRoTOcjk%3D&reserved=0>
> > _______________________________________________
> > SIG-policy - https://mailman.apnic.net/[email protected]/
> > To unsubscribe send an email to [email protected]
>
>
>
> --
> --
> Satoru Tsurumaki
> BBIX, Inc
> _______________________________________________
> SIG-policy - https://mailman.apnic.net/[email protected]/
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