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[rpd] RPD : Policy proposal "Internet Number Resources review by AFRINIC" informations update
Andrew Alston
Andrew.Alston at liquidtelecom.com
Sun Apr 29 14:30:31 UTC 2018
With regards to this policy,
My objections to it again remain – and here are a few more to think about.
1. If AFRINIC wishes to audit usage – they first have to have a process in place to sign water tight NDA’s with strict financial penalties should information about how an ISP is utilizing its space go public – the confidentiality agreement in the current MSA is nowhere near tight enough for any corporate to expose the type of information that may be requested in a detailed review
2. The processes involved in the review are inadequately defined and open to interpretation and hence – open to abuse that could be used to victimise organisations – this must be closed and addressed
3. Dependent on the processes defined for (b) – there could be significant costs for a full IP audit – and I propose that if an audit is conducted and the ISP is found to be compliant – then AFRINIC should be responsible for those costs once a detailed accounting is given – if the ISP is NOT found to be compliant – they can then bear the costs involved
4. Should AFRINIC choose to revoke space on the basis of an IP audit process that is not adequately defined – what is the appeal process to appeal any decision they come to as a result of the review – because failing an external untained and unbiased appeal process by a neutral third party – such a revocation could lead to swift and extremely expensive litigation.
5. I question the NEED for this policy – the ability to do basic reviews is already codified in the MSA despite the issues raised above (which I believe would create similar problems where AFRINIC to ever attempt a full audit) – and hence – I simply see no reason for this policy to even exist
My objections to this policy hence remain on the basis of the above.
Andrew
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