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Database SIG
APNIC Database Privacy Issues
1 March 2001 APRICOT, Malaysia
Fabrina Hossain
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Background
JPNIC raised privacy concerns in Brisbane
DB SIG
Many residential users connecting to internet
through cable and ADSL services
Such assignments need to be registered in a
public whois database
Thus information of private residents being
disclosed
Address, phone, fax etc
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Background
Current JPNIC registration policy
Details collected and registered in database by
ISP for all residential user assignment blocks
Postal addresses, ph and fax numbers of
admin contacts are not disclosed
Proposal for APNIC to adopt similar policy
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Contact Persons
Technical contact (tech-c)
Responsible for technical operation of network
Should be reachable by any means in case of
emergency, security incidents etc
Administrative contact (admin-c)
Responsible for financial, legal and content
matters (etc)
ASIA PACIFIC NETWORK
INFORMATION CENTRE
APNIC Current Practice
Home LAN/SOHO end user assignment
If assignment to end user is more than /30
Update APNIC database inetnum object
Outlining user details in netname: and descr: fields
Include admin-c as end user contact if possible
Onsite admin-c not mandatory, but recommended
Tech-c can be ISP contact
ISP should inform customer of whois registration
/30 assignment considered infrastructure
ASIA PACIFIC NETWORK
INFORMATION CENTRE
APNIC Current Practice
Static assignment
For verification purposes only
If LIR assigns single static IP addresses to
residential users
Must update inetnum in database for each end user
assignment
Admin-c and tech-c can be ISP contacts
Or
When submitting address request APNIC will
request sample customer list with IP addresses
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Other RIR Policies
ARIN
ISP contacts permitted in Point Of Contacts
field (“Coordinator”)
Residential end users assumed to be contactable
via ISP
IP assignment object records netname of end
user, town and state of residence
Records “private residence” in street address
field
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Other RIR Policies
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Other RIR Policy
RIPE NCC
Similar to APNIC policy
Update RIPE database
Onsite admin-c not mandatory, but recommended
Tech-c can be ISP contact
Had recent discussions in db-wg mailing list
Http://www.ripe.net/ripe/mail-archives/db-wg/2000100120010101/threads.html
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Implications
Possible concerns for ISP
ISP willing to be responsible for customer’s
network?
Implications of being an admin contact
Principle not different to dial-up users
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Privacy Laws – Overview (1)
International law
UN and OECD have defined a set of privacy
principles to guide national lawmakers
Most privacy laws require that personal
information is:
Obtained fairly and lawfully
Used only for the original specified purpose
Adequate, relevant and not excessive to purpose
Accurate and up to date
Destroyed after its purpose is completed.
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Privacy Laws – Overview (2)
APNIC position
Australian laws to come into effect at end of
2001
Federal privacy law applies a “light-touch”
legislative framework
Encourages business self-regulation
Businesses/industries may develop their own
privacy codes
Codes must be at least as strong as the 10 National
Privacy Principles (based on OECD principles)
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Privacy Principles – Key Points
Collection
collect only what is necessary
ensure person is advised how the data is to be used
Disclosure
only disclose data in ways consistent with reasonable
expectation
Security
data must be securely protected
Onward transfers
Must take reasonable steps to ensure that information is only
transferred to those who will act in accordance with same
general principles
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Privacy Practices
Practices should remain consistent with
general principles
A cautious approach to personal information
in international law:
Only collect what data is necessary
Make full disclosure of how data is to be used
Limit the use of, and access to, the data to what
is necessary
Protect the data
ASIA PACIFIC NETWORK
INFORMATION CENTRE
Questions?
ASIA PACIFIC NETWORK
INFORMATION CENTRE