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[rpd] [Community-Discuss] Update to Resources review policy proposal
Andrew Alston
Andrew.Alston at liquidtelecom.com
Thu Nov 17 15:16:20 UTC 2016
Serge,
Publishing that a company has been subject of audit is VERY CERTAINLY confidential information.
Secondly, if someone is requesting an audit against someone else – 100% there is an accuser – you do not request an audit of someone without in effect accusing them of something.
Thirdly, an individual can be a member of AfriNIC in their own right – it does not have to be a corporate entity, and this is a key distinction. The data protection act refers to living individuals – the moment you publish anything that contains any information about a person without his consent you can run foul of that act. If I as an individual held space allocated to be my AfriNIC and they were to publish that they did an audit against me, I would argue that they were in violation of that act, and it would be subject to litigation.
If you publish that you audited a company at all – that company has every right to recourse.
Again – I ask you WHY are you refusing to put in this policy that the person being audited gets to know the identity of the complainant so that if the accusation made that caused the audit is frivolous the company being audited has recourse? If all allegations are substantiated and there is reason for the audit – that recourse will never come into play – however, if fallacious accusations are made to force audit to tie up company resources it will. So, by putting it in there, you are merely ensuring that the intent of the policy is followed and anyone who abuses it pays for their actions. Why are you and your fellow authors point blank refusing to look at making the people who are requesting audits accountable for their actions?
Furthermore – let me say this very clearly – any company that is subject to an audit may require an NDA for that audit to happen – if you’ve ever been under financial audit NDA’s are clearly in place between companies and auditors, because by nature audits deal with sensitive information. If a company chose to demand an NDA – there would be zero grounds to refuse such and it would invalidate and conflict with section 3.6.
This policy is not workable – and until the above issues are addressed I honestly believe and am becoming more convinced by the moment that the true intent of this policy is not being stated on this list. Give us the protections we ask to prevent this policy being abused and it may get less *valid and sustained* objections.
Andrew
From: serge ilunga <sergekbk at gmail.com>
Date: Thursday, 17 November 2016 at 17:30
To: Andrew Alston <Andrew.Alston at liquidtelecom.com>
Cc: ALAIN AINA <aalain at nsrc.org>, AfriNIC List <rpd at afrinic.net>
Subject: Re: [rpd] [Community-Discuss] Update to Resources review policy proposal
Andrew,
First of all, once we agreed that the reviews of the allocations/assignments are mandatory in accordance to RSA and policies, it is our collective responsibility to make this policy proposal acceptable to all by proposing amendments.
The number resources reviews are based on compliance with RSA and policies. Why are these questions raised here and not on the RSA and the allocations policies themselves? I found it strange that all of these noises are coming from a board member whose role is to make sure the organisation enforce its rules.
Nevertheless, find below inline, few comments:
On Thu, Nov 17, 2016 at 3:24 AM, Andrew Alston <Andrew.Alston at liquidtelecom.com<mailto:Andrew.Alston at liquidtelecom.com>> wrote:
Ok, Fair point that anyone can request an audit against anyone – now, lets ask some very specific questions which are again, valid concerns and objections that that in order to achieve the definition of consensus have to be addressed.
++++++++++++++++++++
Hmmm. There is no such “prosecutor”vs “accuser” here. AFRNIC allocate public ressources to members based on needs with members bound on reporting usage to AFRINIC all times.
Anyone who think that the ressources are not used as they should have been, can alert AFRINIC which if convinced, may initiative reviews. So it is always AFRINIC vs Members relationship.
See the new 3.3.3 (b) which has been amended to address previous concerns from you.
=============
3.3.3 Reported: Here, members are reviewed either because:
a..They have requested the review themselves or
b. There has been a community complaint made against them that warrants investigation. Complaints shall be backed by evidence and AFRINIC staff shall evaluate the facts as appropriate to conduct the review. However this review is not applicable to a member with the same resources portfolio on which a full review has been completed in the preceding 24 months.
+++++++++++++++++++++++++++
a.) Why to the authors refuse to respond on the issue of allowing the entity to be audited know who requested the audit and under what grounds. Why is there in effect prosecution without the chance to confront the accuser.
b.) Why are the random choices limited to those categories, why should EVERY category not be subject to the same random picks – if you gonna apply it, let it apply globally
c.) Why should AfriNIC publish the list of companies audited, especially if they are found to have clean audits - and not publish the name of the individual that requested the audit along with it
+++++++++++++++++++++++++++
Among concerns raised during previous discussions is the fact that reviews will impose additional burden on staff resulting in additional cost. It was just proposed to make the “random” reviews limited for these categories.
There are few of them, using large proposition of the ressources. They are 2 other classes (“selected” and “reported”) which allow review of all categories of members.
But if you want to extend the “random” class to all categories, it is very easy: propose text to the section 3.3.1.
+++++++++++++++++++++++++++
d.) Why should entities that request an audit not be subject to automatic audit themselves
e.) In the event that resource is held by an individual in their own right please explain to me how this entire policy would not put AfriNIC in direct violation of clause 4.d of the RSA, considering that any investigation into an individual could be classified as sensitive information under the Mauritian Data Protection act of 2004.
+++++++++++++
Ressources held by individual on their “own right” ?
All number ressources allocated are by “right to use” granted by AFRINIC to users under conditions and subject to review. AFRNIC through 4.d of the RSA is committed to comply with all applicable data protection and privacy laws of Mauritius. No problem here…
+++++++++
f.) Please explain what would happen if an individual went through the routing tables, found 300 members that are not announcing space, and requested audits against all 300 of them simultaneously – which under the auspicious of this policy would be an entirely valid thing to do – and where the resources in a company that has less 1/6h of that number in terms of staff is meant to accomplish this
+++++++++++++++++++++++++++
Looking at the routing table to measure the status of the ressources should be done by AFRINIC routinely which may decide to act as per the class “selected”. But in all cases AFRINIC decides at its discretion who to review and when.
+++++++++++++++++++++++++
g.) Please explain to me why anyone requesting an audit, and the audit is found to be frivolous upon investigation should be bare the entire cost of the work done – as is common in civil cases that are found to frivolous
+++++
As said many times, it is up to AFRINIC after evaluation and analysis of the facts and evidences provided, to decide if a review should be conducted or not.
++++++
h.) Explain how AfriNIC is meant to deal with the situation where they may be under NDA with a particular organisation as a result of the fact that said organisation has demanded such in order to submit application information
i.) Please explain how AfriNIC is meant to comply with its own public statements that information about an application is held confidentially – since disclosure of the outcome of an audit to have any meaning will mandate disclosing the original reason for request for IP space
+++++++++++++++++++++++++++++
Section 3.6 reads:
"3.6 Compliance Report
AFRINIC shall publish an annual report describing the members which have been reviewed and their level of compliance."
Publishing level of compliance involve no confidential information.
++++++++++++++++++++++++++++++++++
Every single one of these points reflect lack of detail in this policy ad should be taken as a fundamental and valid objection to this policy unless adequately answered, and the objections shall be sustained unless they are answered fully and addressed directly.
Andrew
Serge I.
From: ALAIN AINA [mailto:aalain at nsrc.org<mailto:aalain at nsrc.org>]
Sent: 16 November 2016 20:31
To: AfriNIC List <rpd at afrinic.net<mailto:rpd at afrinic.net>>
Subject: Re: [rpd] [Community-Discuss] Update to Resources review policy proposal
On Nov 16, 2016, at 8:14 PM, Andrew Alston <Andrew.Alston at liquidtelecom.com<mailto:Andrew.Alston at liquidtelecom.com>> wrote:
I actually disagree with this stance Mark,
I believe that if any member, irrespective of size, is subject to the policy, then policy should apply to ALL members.
I see absolutely no reason that if someone can request an audit on a medium or large member, then by the same token, a member holding a /24 should be subject to the same conditions.
Please read the proposal again http://www.afrinic.net/en/community/policy-development/policy-proposals/1827-internet-number-resources-review-by-afrinic
3.1 The reviews shall be based on compliance with the terms outlined in the RSA and Allocation/Assignment Policies.
3.2 The reviews cover all allocated/Assigned resources, but priority goes to IPv4 and ASN mappable to two-octet ASN.
And the 3.3 defines classes which cover all.
—Alain
I point out at that the vast majority of space that is allocated and not in the tables is held by members who are holding /24s, 23/s and /22s, that analysis was clear.
Also, differentiating between end users and LIR's in this regard is also problematic. If you are going to make people subject to audit under a policy which is rife for witch hunts and abuse - then make EVERYONE subject to it. Anything else again, makes me question the real motivations behind this policy. I have to wonder if this policy not in fact designed so that people can demand audits on specific companies and individuals that they not prepared to name on this, and that the real motivation behind this policy is to give them grounds for a witch hunt rather than having anything to do with conservation or efficient use of resources.
I have these thoughts based on the fact that up until now, no one has shown ANY substantial evidence of resources being used outside of policy, nor have I seen any willingness to put proper protections in place, nor have I seen pre-emptive moves by supports of this policy to justify their usage publically when questioned, despite supporting a policy that if applied to them would mandate that AfriNIC makes public disclosure of the findings of investigations - but curiously enough - I then discover that those same people are not subject to their own audit policy because of their membership category.
I'm not saying anything dodgy is going on here for certain... but I will say that I am beginning to openly question the motivations for the policy and until proven wrong by the authors through proper substantiated evidence, those doubts will linger in my mind, and every member of this list looking at policies like this, should take a long hard introspective look and ensure they understand the true motivations behind the document.
Andrew
-----Original Message-----
From: Mark Elkins [mailto:mje at posix.co.za]
Sent: 16 November 2016 18:40
To: rpd >> AfriNIC Resource Policy <rpd at afrinic.net<mailto:rpd at afrinic.net>>
Subject: Re: [rpd] [Community-Discuss] Update to Resources review policy proposal
What was the motive for this policy?
+------------------------
| stockpiling and non-efficient use
+------------------------
What did it go out to fix in the first place?
A thought in the back of my head is this would be used to mainly audit people with lots of space?
+--------------------------------
| 3.3 Classes of review: Members to be reviewed shall be selected
| according to the following classes:
|
| 3.3.1 Random: The member is chosen by AFRINIC at random between
| members of the following categories:
|
| Medium and above
| IPv6-only Large
| EU-AS
+--------------------------------
So we ignore smallish LIR's
but not smallish EU's
I think less than medium EU's should also be ignored.
Do we really need to include IPv6 today?
+--------------------------------
| 3.3.2 Selected:
|
| A member is selected because of an internal report or due to a lack of
| contact between the AFRINIC and the member.
|
| 3.3.3 Reported: Here, members are reviewed either because:
|
| They have requested the review themselves or There has been a
| community complaint made against them
| that warrants investigation.
+-------------------------------
If people report "out of business" businesses with IP Resources, no problem.
However, it appears that anyone (including a non-member) can call for a review of a large member. Still sounds like an excuse for a witch hunt.
This needs to be much better worded control.
1 - Only Members (preferably in "Good Standing") can file a report.
2 - They can only do so if they are within 50% of the size (in contested address space) of the Member they are calling out. Perhaps a "Group Action" can be established to achieve this requirement.
3 - They can expect to be audited themselves - especially if the requested audit comes out clean.
4 - On the other hand, the AFRINIC Board can always call for an Audit (I trust them).
Anyway, where do I find the complete current Draft? I've been looking at:-
http://afrinic.net/en/community/policy-development/policy-proposals/1827-internet-number-resources-review-by-afrinic
On 16/11/2016 12:43, Andrew Alston wrote:
So,
I have a hypothetical question – and it will become a lot less
hypothetical once I’ve run the numbers which I’m currently doing.
Let’s say we implement this audit policy – and then – because we have
to act consistently – we act against every member who is not
announcing space because they cannot justify not announcing it – and
we terminate their membership.
Are the authors of this policy and those supporting it prepared to
bear the cost of the fee increases that would be necessary to back
fill the loss in revenue that would effectively bankrupt AfriNIC?
Running through the preliminary statistics – firstly the auditing
process would be immensely expensive in HR cost – secondly –
termination of members that aren’t “legitimately” announcing space by
rough calculations could cost AfriNIC in excess of 15% of its revenue
by the latest numbers available in the financial reports and
correlating the unannounced space that is allocated with the billing file.
Now, some would argue that is all the more reason to implement the
audit policy – but here is a wake up call – the space you would
recover in that call on those calculations – amounts to less than 10%
of space that AfriNIC has allocated legitimately since May – so
effectively, for the gain of looking tough and being rigid, we may end
up bankrupting the organisation while recovering potentially a /15 worth of space.
Alternatively, from any logical business perspective – that money
would have to be recovered from the members who are legitimately
announcing space – because it certainly can’t just disappear.
So, has anyone ACTUALLY thought through the implications of this
policy? I remain firmly opposed.
Andrew
*From:*Dewole Ajao [mailto:dewole at forum.org.ng]
*Sent:* 16 November 2016 12:52
*To:* sergekbk <sergekbk at gmail.com<mailto:sergekbk at gmail.com>>; Arnaud AMELINA
<amelnaud at gmail.com<mailto:amelnaud at gmail.com>>; rpd >> AfriNIC Resource Policy
<rpd at afrinic.net<mailto:rpd at afrinic.net>>; General Discussions of AFRINIC
<community-discuss at afrinic.net<mailto:community-discuss at afrinic.net>>
*Subject:* Re: [Community-Discuss] Update to Resources review policy
proposal
I think all policies (if we really intend to implement them) must be
clear and leave no room for variable interpretation as ambiguity will
put additional burdens of interpretation on staff.
If the community's preference is for the 24-month window to become
invalid on allocation/assignment of new resources, then the policy
(proposal) should state it clearly; If on the other hand, the
intention is for the 24-month window to stay in place come-what-may,
it's better for the policy (proposal) to be explicit about it.
Please see below, additional questions for the community to consider.
Hopefully, they can be discussed and the authors can (if they so
choose,) take the inputs from the community into their modified proposal.
3.3.2 Selected:
A member is selected because of an internal report or due to a lack of
contact between the AFRINIC and the member.
Q1. Do we presently have an existing (effective) structure (apart from
billing) that measures degree of contact with members?
If there is no agreed means of measuring the degree contact, we need
to define degrees of contact so that "lack of contact" (as referred to
in the proposal) can be measured objectively.
/Perhaps as a first step for ensuring regular contact without using up
too many resources, this proposal might want to borrow a leaf from
RIPE's Assisted Registry Check (ARC). See
https://www.ripe.net/manage-ips-and-asns/resource-management/assisted-
registry-check/
/Basically, the RIR does a consistency check on members' Registry,
Resource, and Route/rDNS information and then sends emails to the
contacts on file showing their view. They then schedule a telephone
call to work with the member and fix any identified issues. /
/My understanding from RIPE is that these non-invasive checks
sometimes reveal issues that may warrant more detailed investigation.
The primary model is by random checks but done in a manner that checks
every member at least once in 3 years (given the size of RIPE). They
also have ARCs that are initiated as a result of information received
from the member or third parties. /
Q2. Can reachability/cooperation of a member for such a consistency
check-and-fix activity as described above be used to measure the
degree of contact?
Q3. Given the fact that time taken for consistency checks are more
predictable, can these be implemented as a preliminary step in
addressing the "lack of investigation" problem as well as the concern
about taking up much of members' and/or AFRINIC hostmasters' time?
Regards,
Dewole.
(with apologies for continuing the cross-posting between RPD and
Community-discuss)
On 15/11/2016 20:18, sergekbk wrote:
Hello Dewole,
Thanks for this comment.
The limit of 24 months applies to a member based on ressources
portfolio. If the portfolio changes with new allocation, member
can be audited anytime on the new ressources if required.
Is this clear enough or shall we make it explicit ?
Kind Regards.
*/Serge Ilunga/*
*/Cell: +243814443160<tel:%2B243814443160>/*
*/Skype: sergekbk/*
*/R.D.Congo/*
-------- Original message --------
From: Dewole Ajao <dewole at tinitop.com<mailto:dewole at tinitop.com>> <mailto:dewole at tinitop.com>
Date: 11/15/2016 11:38 (GMT+01:00)
To: Arnaud AMELINA <amelnaud at gmail.com<mailto:amelnaud at gmail.com>> <mailto:amelnaud at gmail.com>,
"rpd >> AfriNIC Resource Policy" <rpd at afrinic.net<mailto:rpd at afrinic.net>>
<mailto:rpd at afrinic.net>, General Discussions of AFRINIC
<community-discuss at afrinic.net<mailto:community-discuss at afrinic.net>>
<mailto:community-discuss at afrinic.net>
Subject: Re: [Community-Discuss] Update to Resources review policy
proposal
Thanks for working to apply the community's input to your proposal,
Arnaud.
To test the proposed re-wording, consider the following sequence of
events:
Member XYZ initiates self-requested review;
Review is completed by AFRINIC in X weeks;
After review, Member XYZ applies for "large chunk" of number resources;
Member XYZ receives "large chunk" of number resources in say 60 days;
Member XYZ happens to make some unacceptable use of (previous or
new) number resources and it somehow becomes known to the community;
Regardless of convincing evidence, Member XYZ cannot be subjected to
a review until 24 months have elapsed since the last review.
Is this a design feature or a bug?
Regards,
Dewole.
On 15/11/2016 10:48, Arnaud AMELINA wrote:
Hi community !
Following, recent discussions and in accordance with text
proposal from Owen and others contributors, authors propose this
as replacement to the section 3.3.3
-'---old version---''
3.3.3 Reported: Here, members are reviewed either because:
a. They have requested the review themselves or
b. There has been a community complaint made against them that
warrants investigation.
----new version-----
3.3.3 Reported: Here, members are reviewed either because:
a..They have requested the review themselves or
b. There has been a community complaint made against them that
warrants investigation. Complaints shall be backed by evidence
and AFRINIC staff shall evaluate the facts as appropriate to
conduct the review. However this review is not applicable to a
member on which a full review has been completed in the
preceding 24 months.
Regards.
Arnaud.
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