On Wed, Nov 05, 2014 at 01:31:04AM -0800, Ronald F. Guilmette wrote:
Personal data are defined as "any information relating to an identified or identifiable natural person ("data subject");...
I am asuming that, in this context, "natural person" has the same meaning on both your side of the pond and mine, i.e. a carbon-based life form, and an entity composed of flesh and blood. Does that term have that meaning also within the EU?
You are probably right that the DPD only applies to natural persons, however natural persons also hold independent resources (I personally had both a PI assignment and an ASN at some stage)
% Information related to 'JS6689-RIPE'
So, as I say, I am perplexed. You tell me that RIPE has a legal obligation to protect secrecy/privacy, and I _do_ believe you. The several online articles I've read on the subject this evening are all quite clear that this is indeed correct. Nontheless, the clear evidence which is right
I personally think that publishing "person" objects does indeed break the law, NCC Legal clearly disagrees. TTBOMK, this has never been tested in court. However, there is currently no requirement to have any other info than some contact info in this object, so data hygiene is clearly possible. (it also does not have to be "official" information)
And if, as would seem to be the case, RIPE *has* indeed found a legally viable way to be transparent about certain things... e.g. the entries in its data base... even while still remaining within bounds of EU data protection regulations... then why can it not do so also with respect to all those contracts that it signs with things which are not natural persons?
So there might not be an actual legal obligation to keep these contracts confidential. I'm not even sure now that the general LIR Service Contract (which states that all contractual information is confidential) applies in this case as (in case of a sponsoring LIR) it is not a contract that the NCC is a party to. In any case, this is for NCC Legal to answer, not for me. I'm not sure that the contract contains any relevant information, besides that which is published in the db already. Whatever pricing and other conditions were agreed is none of your business. Whatever documentation is used to verify ID is, in case of passport copies, etc, very much subject to the DPD; in case of registration documents, these are (usually) public information, there may be a copyright issue though as many authorities make these available, but not for free. In any case, I'm sure I'm not the only member whose idea of what we pay the NCC for is to be a resource registry, *not* an intelligence repository for curtain-twitchers and anyone who fancies themselves some kind of Internet Stasi. We already pay taxes for government agencies to be that. rgds, Sascha Luck