Hi Denis, all,

To recap the discussion on this topic: after it was first suggested to introduce geofeed as a new attribute in the RIPE Database, we raised some legal concerns related to its implementation and suggested that technical restrictions are required to minimise the associated legal risks. The main concerns arose because providing geolocation information, including geolocation information that might contain personal data, is not covered under the current purposes of the RIPE Database.

From the discussion on the RIPE Database Working Group mailing list prior to RIPE 85, various feedback was provided on the use of geolocation information and the reasons for which this is useful for network and content operators. At the RIPE 85 Database Working Group session, the Working Group chairs declared there was consensus that geolocation is a purpose the RIPE Database has to fulfil. They also asked for input on the process to follow for amending the current RIPE Database Terms and Conditions and working on a draft purpose. A draft purpose has now been suggested, along with the question of whether this addresses all legal concerns and if we can go ahead with the implementation of the geofeed attribute.

Having established that geolocation is a purpose and looking at the proposed text, our advice is to make this more explicit and explain why personal data may be processed for the purpose of geolocation. We will work on updating the RIPE Database Terms and Conditions in order to specify this. In line with the Adoption Process for RIPE NCC Corporate Documents, the proposed amendments will have to be approved by the RIPE NCC Executive Board.

On the implementation side, we will discuss internally how we can make it explicit when adding a geofeed attribute that the privacy of the users of the related resources is respected. This is necessary because, as mentioned in our previous replies, although the RIPE NCC is not the party inserting the data in the csv file, legally we are co-responsible for the information inserted in the RIPE Database (even if it is not hosted there directly). As with all the other personal data in the RIPE Database, the party that enters it has the responsibility to inform the individual to whom the data pertains and to obtain their explicit consent before entering it (Art. 6.3 RIPE Database Terms and Conditions).

Kind regards,

Maria Stafyla
Senior Legal Counsel
RIPE NCC

On 25/04/2023 11:25, Maria Stafyla wrote:

Hi Denis, all

This is to confirm that we are already working on our analysis and we will get back to you as soon as possible.

Kind regards,

Maria Stafyla
Senior Legal Counsel
RIPE NCC

On 13/04/2023 12:29, denis walker wrote:

Colleagues

A question for the legal team at the RIPE NCC. Would a simple purpose,
as suggested below, address all the concerns you had about the use of
the "geofeed:" attribute and allow you to remove any restrictions you
felt were necessary when it was introduced?

cheers
denis
co-chair DB-WG

---------- Forwarded message ---------
From: denis walker <ripedenis@gmail.com>
Date: Tue, 11 Apr 2023 at 10:41
Subject: Geofeed purpose
To: Database WG <db-wg@ripe.net>

Colleagues

The conversation on deploying geofeed died shortly after RIPE 85. The
last comment was from myself asking if anyone was willing to propose
some wording for a new purpose covering the use of the RIPE Database
for geolocation information. No one proposed any wording. So below I
have made a proposal for a new purpose. Your comments are appreciated.

cheers
denis
co-chair DB-WG

The RIPE Database contains information for the following purposes:

     Ensuring the uniqueness of Internet number resource usage through
registration of information related to the resources and Registrants
     Publishing routing policies by network operators (IRR)
     Facilitating coordination between network operators (network
problem resolution, outage notification etc.)
     Provisioning of Reverse Domain Name System (DNS) and ENUM delegations
     Providing information about the Registrant and Maintainer of
Internet number resources when the resources are suspected of being
used for unlawful activities, to parties who are authorised under the
law to receive such information.
     Scientific research into network operations and topology
     Providing information to parties involved in disputes over
Internet number resource registrations to parties who are authorised
under the law to receive such information.

Providing information about the geolocation usage of Internet number resources.