[arin-ppml] Draft Policy ARIN-2017-5: Equalization of Assignment Registration requirements between IPv4 and IPv6
jcurran at arin.net
Mon Jul 17 10:42:07 EDT 2017
On 17 Jul 2017, at 9:47 AM, hostmaster at uneedus.com wrote:
> This is the problem. ARIN is not a carrier. While disclosure to ARIN to obtain number resources for the connection is OK, Public disclosure by or at the direction of ARIN policy of elements like domain name, name, address and telephone number is not. Since name, address, telephone number and domain name have already been identified have been defined in the order as elements of CPNI that are protected, world disclosure by ARIN or because of ARIN rules would not be a protected disclosure.
> The ISP might also be in trouble for providing the information to ARIN, if they know that ARIN intends to publish this information in a public directory, rather than disclosing it to ARIN solely to maintain number resources. As suggested by the OP, might have to call them customer 1-n. However that would violate the NRPM as written. Since the City, State and Zip Code are part of the address, even the "protected" residential records CPNI are being disclosed in violation of the CPNI Order.
> There is a big difference between disclosure to ARIN for taking care of numbering policy, and disclosure to the entire world. Third party disclosure is the main thing that the CPNI rules are intended to address. That is only permitted when it is needed for the provision of service.
Compliance with registry policy is indeed necessary to receive number resources;
it is up to you to determine whether IP number resources are necessary for provision
of your Internet services.
If you choose not to make use of Internet Numbers Registry System resources for
provision of Internet services (or not assign them to your customers), then that is
your choice. Some ISPs may feel that it is necessary to seek consent of customers
who wish to have public IP number resources assigned in the size that would result in
their publication in the public registry, whereas others may not based on their reading
of applicable regulations regarding handling of CPNI information. Such choices are
an operational and business matter left to each ISP to decide based on their individual
understanding and circumstances.
President and CEO
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