[arin-ppml] Privacy of ARIN registry data (was: Re: Reclamation of Number Resources)
jcurran at arin.net
Sun Jul 17 04:33:11 EDT 2022
> On 16 Jul 2022, at 7:31 AM, Ronald F. Guilmette <rfg at tristatelogic.com> wrote:
> As I have stated at some length, I *do not* agree with that when it comes
> to identifying the name, location and other contact details about the
> business (and/or the natural person) that is the member, and when it comes
> to identifying the names and full contact information of any and all
> officers, directors, shareholders, and/or legal representatives of any
> given member that are known to ARIN. All of that information for *all*
> members should *already* be out on the table, and public, totally independent
> of any cases of "fishy facts”.
To be clear, ARIN has the full organization name and its address publicly visible in the ARIN registry.
We used to encourage organizations to use entries for their administrative and technical contact which
consisted of actual (natural) people (including their name/address/email/phone) but no longer do so
because it is unclear that there is specific and legitimate purpose for doing so. Organizations can
continue to use natural people for their contacts if they choose (as opposed to organizational role
accounts), but bear the burden of obtaining the consent of the affected individuals and taking on the
responsible for the ongoing accurate maintenance of such data.
If you wish the ARIN registry to obtain and/or publish “the names and full contact information of any
and all officers, directors, shareholders, and/or legal representatives of any given member”, you would
need to propose a policy that clearly notes the necessary purpose for the collection and processing for
this information, and have the ARIN community concur and adopt said policy. Absent such a policy,
what you seek would represent a fairly significant departure from what are becoming commonly
accepted principles for personal data privacy and processing of personally identifiable information.
President and CEO
American Registry for Internet Numbers
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