Colleagues I have spent some time thinking about the wording of the current purpose of the RIPE Database in relation to geolocation services. In some ways the purposes are very loosely written. That means they are open to interpretation. I think they can be interpreted to cover the "geofeed:" attribute. Some people have expressed this view but it is not sufficient to just say it, you need to justify the viewpoint. I will attempt to do that. "Facilitating coordination between network operators (network problem resolution, outage notification etc.)" The first point is the 'etc'. That means the example list is not exclusive. It doesn't even define the types or categories of coordination. So basically any coordination between network operators is included. 'Facilitating' means 'to make things easy'. So the database exists to make any coordination activity between network operators easy. So in what ways is "geofeed:" going to make it easy for network operators to coordinate some activity? One of the ways network operators have talked about how they want/need to use "geofeed:" data is to provide content based on location of an IP address. If a content providing network operator wishes to offer this content to anyone in a specific location, that can be seen as a coordination activity. The content provider can coordinate with other network operators to establish that their customers are within this location so they can access this content. If this interpretation is accepted by the community then the context has changed. The legal team can now reassess their advice in the context that the use of the "geofeed:" data is now covered by the existing database purposes. But there are other questions that the legal team also needs to consider. The "geofeed:" attribute references data external to the RIPE Database that neither the RIPE NCC nor the RIPE community has any control, management or perhaps even influence over. This data may contain PII. Although the maintainer of that external data is responsible for its content, does the RIPE NCC have any (joint) accountability or liability as the data controller and facilitator of the RIPE Database? Nic Handles are considered to be PII as they reference objects that contain PII. But these objects are also contained within the RIPE Database. The geofeed csv files are external to the RIPE Database. Do the references to them still constitute PII? Given that we are currently discussing a policy proposal governing the use of personal data in the RIPE Database, here we have a mechanism where resource holders can publish full postal address details of end users who are natural persons and link that published data to the resources in the RIPE Database. Given that these files are published by holders of RIPE resources and referenced by the RIPE Database, should the content of these files follow RIPE policies? (I'm not suggesting any validation of the contents, but perhaps resource holders should be responsible for applying policies to this content.) The T&C is a legal document. In the event of any dispute, lawyers make a lot of money by analysing and interpreting documents like this. Although the loosely written purposes may now be interpreted to cover geolocation data, there are still significant problems with the way the purposes are written. A review would still be beneficial. The T&C are mostly in the background during day to day operations. Just as the terms of an insurance policy can be irrelevant for years. The one time it matters is when you want to make a claim, or in the case of the database if someone ever makes a legal challenge over any aspect of its use or content. At that point, if the purposes can be widely interpreted, then the outcome is uncertain. It would be advantageous to all parties if the purposes were clear and precise with little room for interpretation. Whenever this issue is raised some people make the cynical comments that there has never been any legal challenge and there is no queue of people waiting to do so and common sense has always prevailed (in the past). It only needs one. Other RIRs have been involved in legal actions. Don't wait until your house is flooded before checking your insurance policy to see if you are covered. Another clear issue with this purpose's wording is that use of contact details in the database is only allowed by network operators to contact other network operators ("between network operators"). In this sense the purpose is very precise. Use of contact details by the public, non member organisations, investigators, CSIRT teams (unless they are also operators) and LEAs is not allowed under these T&C. Something to think about... cheers denis co-chair DB-WG
Hi, A small comment inline: On Thu, 4 Aug 2022, denis walker via db-wg wrote: (...)
So in what ways is "geofeed:" going to make it easy for network operators to coordinate some activity? One of the ways network operators have talked about how they want/need to use "geofeed:" data is to provide content based on location of an IP address.
Yes. Although *some* geolocation providers INSIST that their location assessment is better than the owner's network. They do this by ignoring messages or form data sent by owners. Keeping the attribute in the RIPE database may show ANYONE what is the location the owner says it is the correct location. And hopefully that should be the mandatory source for this information.
If a content providing network operator wishes to offer this content to anyone in a specific location, that can be seen as a coordination activity. The content provider can coordinate with other network operators to establish that their customers are within this location so they can access this content. If this interpretation is accepted by the community then the context has changed. The legal team can now reassess their advice in the context that the use of the "geofeed:" data is now covered by the existing database purposes.
Yes, please :-) Cheers, Carlos
Hi Carlos On Thu, 4 Aug 2022 at 19:24, Carlos Friaças <cfriacas@fccn.pt> wrote:
Hi,
A small comment inline:
On Thu, 4 Aug 2022, denis walker via db-wg wrote:
(...)
So in what ways is "geofeed:" going to make it easy for network operators to coordinate some activity? One of the ways network operators have talked about how they want/need to use "geofeed:" data is to provide content based on location of an IP address.
Yes. Although *some* geolocation providers INSIST that their location assessment is better than the owner's network. They do this by ignoring messages or form data sent by owners.
Keeping the attribute in the RIPE database may show ANYONE what is the location the owner says it is the correct location. And hopefully that should be the mandatory source for this information.
I have heard this said before. But this is where the wording of the database purposes and use cases for "geofeed:" are critical. If this was the main reason for "geofeed:" it would not be covered by the current purposes. This is a single operator using the RIPE Database to make an announcement or a statement about some aspect of their resources to anyone. It is not 'coordination between network operators', even though the announced information could be used by other operators as well as anyone else. If you look back at the early docs on the registry, geolocation data is not part of the registration data. So none of the current purposes would cover this aspect. It does seem to be a perfectly reasonable use of the RIPE Database for resource holders to provide information about the resources to a wide variety of people, not only other operators. This is why, as I keep saying, we need to have a wider discussion about how people use the database today and review the old defined purposes. I know the purposes of the RIPE Database are the 'elephant in the room'. No one wants to talk about them, review them, touch them, consider them in any way. But they are critical in so many ways. To review and re-write them is not an easy task. That is why the Database Task Force should have started with such a review, but unfortunately they didn't. I know a lot of people wish I would just shut up about the purposes...but we must have this discussion. The historical purposes written in the 1990s (and partially reviewed in 2010) are perhaps not fit for purpose in the 2020s. Maybe the RIPE Database purposes need to be defined by a RIPE policy. I am considering making a policy proposal on this, which will force the discussion... cheers denis co-chair DB-WG
If a content providing network operator wishes to offer this content to anyone in a specific location, that can be seen as a coordination activity. The content provider can coordinate with other network operators to establish that their customers are within this location so they can access this content. If this interpretation is accepted by the community then the context has changed. The legal team can now reassess their advice in the context that the use of the "geofeed:" data is now covered by the existing database purposes.
Yes, please :-)
Cheers, Carlos
denis walker wrote:
If this was the main reason for "geofeed:" it would not be covered by the current purposes. This is a single operator using the RIPE Database to make an announcement or a statement about some aspect of their resources to anyone. It is not 'coordination between network operators', even though the announced information could be used by other operators as well as anyone else. If you look back at the early docs on the registry, geolocation data is not part of the registration data. So none of the current purposes would cover this aspect. It does seem to be a perfectly reasonable use of the RIPE Database for resource holders to provide information about the resources to a wide variety of people, not only other operators. This is why, as I keep saying, we need to have a wider discussion about how people use the database today and review the old defined purposes. I know the purposes of the RIPE Database are the 'elephant in the room'...
FWIW adding a purpose for the RIPE DB of "allowing the resource holders a place to make available to the public information related to those resources" seems perfectly reasonable to me. Best regards -- INCIBE-CERT - Spanish National CSIRT https://www.incibe-cert.es/ PGP keys: https://www.incibe-cert.es/en/what-is-incibe-cert/pgp-public-keys ==================================================================== INCIBE-CERT is the Spanish National CSIRT designated for citizens, private law entities, other entities not included in the subjective scope of application of the "Ley 40/2015, de 1 de octubre, de Régimen Jurídico del Sector Público", as well as digital service providers, operators of essential services and critical operators under the terms of the "Real Decreto-ley 12/2018, de 7 de septiembre, de seguridad de las redes y sistemas de información" that transposes the Directive (EU) 2016/1148 of the European Parliament and of the Council of 6 July 2016 concerning measures for a high common level of security of network and information systems across the Union. ==================================================================== In compliance with the General Data Protection Regulation of the EU (Regulation EU 2016/679, of 27 April 2016) we inform you that your personal and corporate data (as well as those included in attached documents); and e-mail address, may be included in our records for the purpose derived from legal, contractual or pre-contractual obligations or in order to respond to your queries. You may exercise your rights of access, correction, cancellation, portability, limitationof processing and opposition under the terms established by current legislation and free of charge by sending an e-mail to dpd@incibe.es. The Data Controller is S.M.E. Instituto Nacional de Ciberseguridad de España, M.P., S.A. More information is available on our website: https://www.incibe.es/proteccion-datos-personales and https://www.incibe.es/registro-actividad. ====================================================================
I, for one, with my regular internet user hat on, am strongly against any form of geolocation and consider it an invasion of my privacy. I don't want any random guy on the internet to simply pinpoint the town I'm living in. Is there an opt-out from this? Users will demand that there is for sure. Just my $0.02 Agoston On Thu, Aug 4, 2022 at 7:24 PM Carlos Friaças via db-wg <db-wg@ripe.net> wrote:
Hi,
A small comment inline:
On Thu, 4 Aug 2022, denis walker via db-wg wrote:
(...)
So in what ways is "geofeed:" going to make it easy for network operators to coordinate some activity? One of the ways network operators have talked about how they want/need to use "geofeed:" data is to provide content based on location of an IP address.
Yes. Although *some* geolocation providers INSIST that their location assessment is better than the owner's network. They do this by ignoring messages or form data sent by owners.
Keeping the attribute in the RIPE database may show ANYONE what is the location the owner says it is the correct location. And hopefully that should be the mandatory source for this information.
If a content providing network operator wishes to offer this content to anyone in a specific location, that can be seen as a coordination activity. The content provider can coordinate with other network operators to establish that their customers are within this location so they can access this content. If this interpretation is accepted by the community then the context has changed. The legal team can now reassess their advice in the context that the use of the "geofeed:" data is now covered by the existing database purposes.
Yes, please :-)
Cheers, Carlos
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It is an optional attribute and as far as I know it is going to stay that way. -Cynthia On Mon, 22 Aug 2022, 10:13 Horváth Ágoston János via db-wg, <db-wg@ripe.net> wrote:
I, for one, with my regular internet user hat on, am strongly against any form of geolocation and consider it an invasion of my privacy. I don't want any random guy on the internet to simply pinpoint the town I'm living in.
Is there an opt-out from this? Users will demand that there is for sure.
Just my $0.02
Agoston
On Thu, Aug 4, 2022 at 7:24 PM Carlos Friaças via db-wg <db-wg@ripe.net> wrote:
Hi,
A small comment inline:
On Thu, 4 Aug 2022, denis walker via db-wg wrote:
(...)
So in what ways is "geofeed:" going to make it easy for network operators to coordinate some activity? One of the ways network operators have talked about how they want/need to use "geofeed:" data is to provide content based on location of an IP address.
Yes. Although *some* geolocation providers INSIST that their location assessment is better than the owner's network. They do this by ignoring messages or form data sent by owners.
Keeping the attribute in the RIPE database may show ANYONE what is the location the owner says it is the correct location. And hopefully that should be the mandatory source for this information.
If a content providing network operator wishes to offer this content to anyone in a specific location, that can be seen as a coordination activity. The content provider can coordinate with other network operators to establish that their customers are within this location so they can access this content. If this interpretation is accepted by the community then the context has changed. The legal team can now reassess their advice in the context that the use of the "geofeed:" data is now covered by the existing database purposes.
Yes, please :-)
Cheers, Carlos
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Hi It is optional for the resource holder, not for the end user or customer. For them it is a question of whether or not the contracts they signed permit the publication of this (personal) data. cheers denis co-chair DB-WG On Mon, 22 Aug 2022 at 11:30, Cynthia Revström via db-wg <db-wg@ripe.net> wrote:
It is an optional attribute and as far as I know it is going to stay that way.
-Cynthia
On Mon, 22 Aug 2022, 10:13 Horváth Ágoston János via db-wg, <db-wg@ripe.net> wrote:
I, for one, with my regular internet user hat on, am strongly against any form of geolocation and consider it an invasion of my privacy. I don't want any random guy on the internet to simply pinpoint the town I'm living in.
Is there an opt-out from this? Users will demand that there is for sure.
Just my $0.02
Agoston
On Thu, Aug 4, 2022 at 7:24 PM Carlos Friaças via db-wg <db-wg@ripe.net> wrote:
Hi,
A small comment inline:
On Thu, 4 Aug 2022, denis walker via db-wg wrote:
(...)
So in what ways is "geofeed:" going to make it easy for network operators to coordinate some activity? One of the ways network operators have talked about how they want/need to use "geofeed:" data is to provide content based on location of an IP address.
Yes. Although *some* geolocation providers INSIST that their location assessment is better than the owner's network. They do this by ignoring messages or form data sent by owners.
Keeping the attribute in the RIPE database may show ANYONE what is the location the owner says it is the correct location. And hopefully that should be the mandatory source for this information.
If a content providing network operator wishes to offer this content to anyone in a specific location, that can be seen as a coordination activity. The content provider can coordinate with other network operators to establish that their customers are within this location so they can access this content. If this interpretation is accepted by the community then the context has changed. The legal team can now reassess their advice in the context that the use of the "geofeed:" data is now covered by the existing database purposes.
Yes, please :-)
Cheers, Carlos
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participants (5)
-
Carlos Friaças -
Cynthia Revström -
denis walker -
Horváth Ágoston János -
Ángel González Berdasco