[sig-db]Database SIG proposal: Privacy of Customer Assignment Records

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  • Subject: [sig-db]Database SIG proposal: Privacy of Customer Assignment Records
  • From: "Paul Wilson" <pwilson at apnic dot net>
  • Date: Tue, 22 Jul 2003 17:40:33 +1000
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      Attached is a policy paper for the Database SIG at APNIC 16.
      Please feel free to send comments or questions to this list, or to me by
      Hope to see you in Seoul,
      Paul Wilson, Director-General, APNIC                      <dg at apnic dot net>
      http://www.apnic.net                            ph/fx +61 7 3858 3100/99
      See you at APNIC 16
      Seoul, Korea, 19-22 August 2003            http://www.apnic.net/meetings
      Privacy of Customer Assignment Records
      Proposed by: Paul Wilson, APNIC Secretariat
      Version: 1.0
      Date: 18 July 2003
      1    Summary
      In this document it is proposed that customer assignment
      records of APNIC Member ISPs need no longer be publicly
      accessible in the APNIC database.  These registrations are
      essential to the verification of resource utilisation during
      the address request process, however for a number of reasons
      it is no longer desirable that they must necessarily be
      publicly available. ISPs wishing to register and maintain
      customer assignments publicly should be able to do so;
      however a new database attribute will allow the records to
      be hidden from public view if desired.
      2    Background and Rationale
      2.1  Privacy Concerns
      In recent years, increasing concern about protection of
      private information on the Internet has been expressed by
      many parts of the community, and through conventions and
      legislation, in most parts of the world.  Within the APNIC
      member community, concern has been expressed specifically
      about the requirement to publicly register customer
      assignments, which are often regarded by ISPs and customers
      as private information.
      Furthermore, in certain jurisdictions an organisation which
      publishes data on behalf of other parties may be held to be
      jointly responsible for the accuracy of this information.
      This may place APNIC itself at risk, in case of damages
      caused by inaccurate customer assignment information.
      2.2  Registration Goal
      Accurate resource registration is a fundamental goal of
      Internet resource management, however it is important to
      recognise which types of registration are essential to this
      goal, and which registration records can be feasibly
      maintained and controlled under APNIC policies.
      APNIC members are obliged under current policies to maintain
      accurate customer assignment records in the database.
      Realistically, this is an onerous and expensive task which
      can often not be performed in a complete or timely manner,
      and as a consequence many assignment records are inaccurate.
      Because the APNIC Secretariat can have no direct control
      over these registrations, it is inevitable that incorrect
      records will continue to exist, compromising the overall
      registration goal.
      On the other hand, records pertaining to allocations and
      assignments which are made by the APNIC registry to its
      members and customers are essential to the resource
      registration goal.  In case of technical problems related to
      the address space concerned, these records identify the
      party which is responsible for the resources concerned.
      These records are far fewer in number and can be maintained
      in an accurate state.
      3    Proposal
      It is proposed that customer assignments (and sub-allocation
      records) need no longer be publicly accessible in the APNIC
      database via normal "whois" queries.
      Customer registration records must still be registered
      within the APNIC database, in order to document address
      utilisation, however a new "hidden:" database attribute will
      be provided to allow the records to be excluded from public
      whois query results.
      ISPs may wish to register and maintain public registrations,
      in order that customer contact information be available
      publicly, however should be their choice. By doing so, ISPs
      must also commit to maintenance of accurate records, and
      APNIC should explicitly disclaim responsibility for accuracy
      of these records.
      A management interface for customer assignments will be
      provided within the "MyAPNIC" service, in order that address
      space utilisation may be tracked.
      4    Implementation
      The following steps are involved in implementation of this
        a.   Provision of a "hidden:" attribute within the APNIC
           database, for use with "inetnum", "inet6num" and "autnum"
           objects (if this attribute is included with value "yes", the
           record will not be visible in public whois queries, and it
           will not be exported to any database mirrors);
        b.   modification of the "MyAPNIC" service to allow
           maintenance of "hidden" records;
        c.   modification of APNIC policy documentation to reflect
           the above changes.
      If is proposed to implement this policy within six months of
      approval by the APNIC community.