[arin-ppml] Draft Policy 2010-3: Customer Confidentiality

[Martin Hannigan]

On Feb 2, 2010, at 1:09 PM, Member Services wrote:


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>
> Draft Policy 2010-3
> Customer Confidentiality
>
> Version/Date: 2 February 2010
>
> Policy statement:
>
> ISPs may choose to enter the customer's name along with the ISP's
> address and phone number in reassignments and reallocations in lieu of
> the customer's address and phone number.

If city, state, and zip (equivalents for non US) were added to this  
that I might support it. We can already nail them down to their  
neighborhoods with geo-location. Omitting the pinpoint address seems  
reasonable. I think maintaining a minimum level of neutrality is  
healthy in this case. While some of our participants would like to use  
us to control their competition I don't think that we should take the  
bait. I think that we should instead be reasonable and make some  
simple modifications that will raise the difficulty level to that off  
other existing methods for engaging in competitive conduct.


>  The customer's actual
> information must be provided to ARIN on request and will be held in  
> the
> strictest confidence.


This is not workable from my perspective. I see no reason to insert  
ARIN in the loop and this will only introduce confusion. Some will  
think that they can now refuse to service subpoenas for subscriber  
information and deflect them to ARIN. I would also think  (only  
because I have significant experience in this area, IANAL) that this  
may not be CALEA compliant if implemented with this activity. Even  
though our job is not to minimize liability for people that don't do  
it themselves, I think that rejecting this proposal based on this  
section alone is prudent for the good of all.

Finally if implemented as is, this will raise ARIN's costs and  
ultimately be unfairly distributed to the rest of us through our  
annual fees.

I would support this proposal if:

    1. Add city, state and zip (equivalents for non US locations)
    2. Removed ARIN, Inc. requirements related to address (with)holding
    3. Was sound from a regulatory perspective including items 1 and 2


Best,

Martin