ARIN-PPML Message

[ppml] Policy Proposal 2004-7: Residential Customer Privacy Policy

Concerning the proposed policy, Residential Customer Privacy Policy, which
was posted to PPML on August 20, 2004, the ARIN Advisory Council supports
moving the proposed policy (as is) forward in the evaluation process.

ARIN welcomes feedback and discussion about this policy proposal in the
weeks leading to the ARIN Public Policy Meeting in Reston, Virginia
scheduled for October 20-21, 2004.

According to the ARIN Internet Resource Policy Evaluation Process the
Advisory Council will evaluate policy proposals after the Public Policy
Meeting. The feedback and discussion of policy proposals on the Public
Policy Mailing List will be included in the AC's evaluation.

Subscription information for the ARIN Public Policy Mailing List can be
found at:

	http://www.arin.net/mailing_lists/index.html

The ARIN Internet Resource Policy Evaluation Process can be found at:

	http://www.arin.net/policy/ipep.html

ARIN's Policy Proposal Archive can be found at:

	http://www.arin.net/policy/proposal_archive.html

The policy proposal text is below and can be found at:

	http://www.arin.net/policy/2004_7.html

Regards,

Member Services
American Registry for Internet Numbers (ARIN)


### * ###


Policy Proposal 2004-7: Residential Customer Privacy Policy

Author: William Leibzon

Policy statement:

An organization with downstream residential customer who is not engaged in
business activities may substitute that organization's name for the
customer's name, e.g. 'Private customer - XYZ Network', and the customer's
street address may read 'Private Residence'. Each private downstream
residential reassignment must be less then or equal to 128 ips and have
accurate upstream Abuse and Technical POCs visible on the WHOIS record for
that block.

Rationale:

The intent of residential customer privacy was to allow private citizens
to have privacy and safety in their personal life while being able to
request and use more then 8 ip addresses with residenial dsl line.

However soon after implementation it became clear that some of the ip
blocks being designated as "Private customer" are being used for business
purposes which is clearly seen by size of such reassignments as
69.111.160.0/22. While it is not unexpected that some people may run
business (including internet businesses) from their home, the laws regard
such activity as being similar to running business from small office and
usually require such businesses to receive a license from appropriate
local or state agency and to disclose the activity to the public, as such
different privacy rules apply in these situations.

This policy replaces current residential customer privacy 2003-3 and
requires that ISPs only designate reassignment whois data as "Private
Customer" if no business activity is involved with use of the ip block.
The limit for the reassignment is set to 128 ips as larger number of
computers in one residence is likely an indication of business activity
(as an example currently telephone companies allow up to 4 residential
telephone lines and if somebody needs larger number of telephone lines to
his home, those must be purchased as business telephone lines).
Additionally the amendment fixes small grammer error in current policy
text that involves incorrect use of plural and singular tenses.