Thanks Vivek, To determine a rough order of magnitude of the number of users impacted by this policy, could I ask that you provide figures on the number of unique source IP addresses that have made Whois queries to whois.apnic.net over the last several months (6-12 if possible)? Would it also be possible to compare that to the number of queries using RDAP?
Regards, Liam Stephens General From: Vivek Nigam <[email protected]> Sent: Thursday, 20 February 2025 12:36 PM To: Stephens, Liam <[email protected]>; Christopher Hawker <[email protected]>; Tsurumaki, Satoru <[email protected]>; [email protected]; Jonathan Brewer <jon@tō.nz> Subject: Re: [sig-policy] Re: New version : prop-162: WHOIS Privacy v002 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]<mailto:[email protected]>> Date: Wednesday, 19 February 2025 at 9:39 pm To: Vivek Nigam <[email protected]<mailto:[email protected]>>, Christopher Hawker <[email protected]<mailto:[email protected]>>, Tsurumaki, Satoru <[email protected]<mailto:[email protected]>>, [email protected]<mailto:[email protected]> <[email protected]<mailto:[email protected]>>, Jonathan Brewer <[email protected]<mailto:[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<mailto:[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<mailto:[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]<mailto:[email protected]>> Sent: Wednesday, 19 February 2025 2:39 PM To: Stephens, Liam <[email protected]<mailto:[email protected]>>; Christopher Hawker <[email protected]<mailto:[email protected]>>; Tsurumaki, Satoru <[email protected]<mailto:[email protected]>>; [email protected]<mailto:[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]<mailto:[email protected]>> Date: Wednesday, 19 February 2025 at 11:28 am To: Christopher Hawker <[email protected]<mailto:[email protected]>>, Tsurumaki, Satoru <[email protected]<mailto:[email protected]>>, [email protected]<mailto:[email protected]> <[email protected]<mailto:[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<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]<mailto:[email protected]>> Sent: Wednesday, 19 February 2025 11:53 AM To: Tsurumaki, Satoru <[email protected]<mailto:[email protected]>>; [email protected]<mailto:[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<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]<mailto:[email protected]>> Sent: Wednesday, February 19, 2025 11:09 AM To: [email protected]<mailto:[email protected]> <[email protected]<mailto:[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]<mailto:[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]<mailto:[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 > [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/ > _______________________________________________ > SIG-policy - https://mailman.apnic.net/[email protected]/ > To unsubscribe send an email to > [email protected]<mailto:[email protected]> -- -- Satoru Tsurumaki BBIX, Inc _______________________________________________ SIG-policy - https://mailman.apnic.net/[email protected]/ To unsubscribe send an email to [email protected]<mailto:[email protected]>
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