[rpd] New Proposal - "Internet Number Resources Audit by AFRINIC (AFPUB-2016-GEN-001-DRAFT01)"

[Andrew Alston]

> Section 4 of the Registration Service Agreement (RSA) provides the framework for investigations of the usage of allocated Internet Number resources, defines members’ obligation to cooperate and the measures to be taken by AFRINIC
> in case of failure to comply.

> The lack of such investigation or regular control can lead to inefficient usage of the Internet Number resources, to stockpiling and other types of abuse.

+1 to what McTim said, does anyone have evidence this hasn’t been happening or are we just passing policy because of some vague theoretical fear?

> c) Reported:
> The members have requested the audit themselves or there has been a community complaint made against them that requires investigation.

  And here in lies the problem.  Define such a complaint?  Define the prevention for abuse here? Define the evidence required for the complaint to be taken seriously?  What would happen if a particular member were to send an email to AfriNIC complaining about every single one of his competitors in a particular market?  Under the current wording, AfriNIC would be required to audit all of his competitors, wasting time, wasting money, wasting resources (both AfriNIC’s and all of his competitors)

The proposed wording and definition does not define the basis for the complaint, and it does not require that there be prima facie evidence of wrong doing before someone can force an audit.  That leaves the whole thing HUGELY open to abuse in an industry where there are plenty of corporates out there who would like nothing better than to make life difficult for their competitors.

Further to this – at the very least can we say that all complaints should be A.) Official B.) Backed by Evidence and C.) PUBLIC.  This is at the very least a means for preventing wholesale abuse of the policy, since it means that anyone making an accusation is legally accountable for said accusation and can be sued if the accusations are completely spurious in nature.

I would also say that once a complaint has been received, it should be entirely at AFRINIC’s discretion if an audit should be conducted at all.  Because AFRINIC may have FAR more information than the person doing the whining and an audit may not be justified AT ALL.

Andrew
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