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[rpd] Assisted Registry Checks
Dewole Ajao
dewole at forum.org.ng
Mon Jun 24 20:37:18 UTC 2019
[was Re: [rpd] Proposal Update received: Internet Number Resources
Review by AFRINIC]
With the type of audit/review being discussed, the costs may vary
significantly from member to member - whether AFRINIC-side or Member-side.
I have however in the past mentioned that RIPE NCC has something simple
and time-efficient called Assisted Registry Checks and if I remember
correctly, they aim to check records for every member once in two years.
While we await the audit/review/recovery policy, it would be nice to see
AFRINIC start to implement basic checks (even before a member comes for
a repeat allocation).
See
https://www.ripe.net/manage-ips-and-asns/resource-management/assisted-registry-check
These are simple checks to ensure registry accuracy and I see no reason
why anyone would try to discourage AFRINIC from checking the accuracy of
its records with the assistance of members.
This first step we can all agree on and staff can implement almost
immediately (in addition to the work they are already doing when members
come to them with issues arising from our lame-delegations and
no-reverse-unless-assigned policies).
Regards,
Dewole.
On 6/24/2019 7:20 PM, JORDI PALET MARTINEZ via RPD wrote:
> Hi Ish,
>
> I understand that, but my point is that there are two sides of the cost. And both should be considered:
>
> a) The cost for Afrinic (lets talk about average) for each review to an ISP.
>
> b) The cost for each member being reviewed (again we can get examples to calculate an average).
>
> Regards,
> Jordi
> @jordipalet
>
>
>
> El 24/6/19 20:00, "Ish Sookun" <ish.sookun at lasentinelle.mu> escribió:
>
> I only requested an indicative value. I didn't ask to consider all
> possibilities (e.g litigation, big or small ISP etc). The idea is to
> obtain an approximate cost figure to evaluate whether the mere
> implementation of this policy brings a financial burden on AfriNIC.
>
> Regards,
>
> Ish Sookun
>
> On 6/24/19 7:31 PM, JORDI PALET MARTINEZ via RPD wrote:
> > I think there is one more cost to be considered here as well.
> >
> >
> >
> > Each time an ISP gets the audit, it will need to dedicate staff for that.
> >
> >
> >
> > It is dificult to calculate “how much” that means, as it may depend on
> > many factors, such as how big is the ISP, how many resources they have,
> > how many customers from different types (business, residential), what
> > provisioning system they have, IPAM if any, level of “automation” and
> > “inventory” of the network, etc.
> >
> >
> >
> > May be it is a good exersice for some of you to calculate (rought idea),
> > how much staff/resources and how many weeks, this will take to you, if
> > the policy it is implemented?
> >
> >
> >
> > A few examples, could help the community to take a decision.
> >
> >
> >
> > Regards,
> >
> > Jordi
> >
> > @jordipalet
> >
> >
> >
> >
> >
> >
> >
> > El 24/6/19 17:25, "Timothy Ola Akinfenwa" <akin.akinfenwa at uniosun.edu.ng
> > <mailto:akin.akinfenwa at uniosun.edu.ng>> escribió:
> >
> >
> >
> > Hello Andrew,
> >
> > While I also agree that Staff provide information on the likely
> > financial implication for the audit, I don't understand why there should
> > be a separate allocation for litigation.
> >
> >
> >
> > Is it wise for an organisation to budget funds for likely court cases
> > when instead they should strive to prevent one in the first place?
> >
> >
> >
> > For me, I think it is critical to ensure that Staff actions on any audit
> > review does not amount to litigation. And this may be captured as a
> > suggestion in the policy as well, if necessary.
> >
> >
> >
> > Best!
> >
> > Sent from my OnePlus mobile device! </>$aa;
> >
> >
> >
> > On Mon, 24 Jun 2019, 3:53 PM Andrew Alston,
> > <Andrew.Alston at liquidtelecom.com
> > <mailto:Andrew.Alston at liquidtelecom.com>> wrote:
> >
> > I would agree that these numbers would be useful - and must in
> > addition include contingent liability allocation for litigation that
> > could result due to implementation of this policy
> >
> >
> >
> > Andrew
> >
> >
> >
> > Liquid Telecommunications - Group Head Of IP Strategy
> >
> > ------------------------------------------------------------------------
> >
> > *From:*Ish Sookun <ish.sookun at lasentinelle.mu
> > <mailto:ish.sookun at lasentinelle.mu>>
> > *Sent:* Monday, June 24, 2019 5:39:19 PM
> > *To:* rpd at afrinic.net <mailto:rpd at afrinic.net>
> > *Subject:* Re: [rpd] Proposal Update received: Internet Number
> > Resources Review by AFRINIC
> >
> >
> >
> > Dear PDWG Co-Chairs,
> >
> > It was expressed during the last meeting that this policy will have
> > financial implications on AfriNIC due to costs associated to auditing.
> >
> > Is it possible to obtain an approximate cost figure (from staff) that
> > such audits would entail?
> >
> > Regards,
> >
> > Ish Sookun
> >
> > On 6/8/19 10:24 PM, Dewole Ajao wrote:
> > > Dear PDWG members,
> > >
> > > This is to inform you that authors of the policy proposal named
> > "Internet Number Resources Review by AFRINIC" have submitted an
> > updated version (Draft version 8) as included below. The URL will be
> > shared once published online.
> > >
> > > Please take some time to go through the proposal contents and
> > provide your feedback.
> > >
> > > Thank you.
> > > PDWG Co-Chairs
> > >
> > >
> > > ------------------------------------------------------------
> > >
> > > ------------------- Begin
> > >
> > ---------------------------------------------------------------------------------
> > >
> > > Name : Internet Number Resources Review by AFRINIC (Draft 8)
> > > Ref. Name: AFPUB-2016-GEN-001-DRAFT08
> > > Status: Under Discussion
> > > Date: 7 June 2019
> > >
> > > Authors:
> > > (a) Amelina A. A. Arnaud | <arnaud.amelina at togorer.tg
> > <mailto:arnaud.amelina at togorer.tg>
> > > <mailto:arnaud.amelina at togorer.tg
> > <mailto:arnaud.amelina at togorer.tg>>> | AUF/TogoRER
> > > (b) Jean-Baptiste Millogo |<jean.millogo at orange.com
> > <mailto:jean.millogo at orange.com>
> > > <mailto:jean.millogo at orange.com
> > <mailto:jean.millogo at orange.com>>>| Orange Burkina
> > > (c) Marcus ADOMEY <madomey at ug.edu.gh
> > <mailto:madomey at ug.edu.gh>
> > > <mailto:madomey at ug.edu.gh <mailto:madomey at ug.edu.gh>>> |
> > University of Ghana
> > >
> > > 13.0 Summary of the Problem Being Addressed by this Policy Proposal
> > >
> > > As Internet Number resources are finite, their allocation is based on
> > > the operational needs of end-users and Internet Services Providers,
> > > while avoiding stockpiling in accordance with RFC7020, IPv4 Allocation
> > > Policy CPM 5.5, IPv6 Allocation and assignment policy CPM 6.5 and
> > Policy
> > > for Autonomous System Numbers (ASN) Management in the AFRINIC
> > region CPM
> > > 7.0.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 type of abuses.
> > >
> > > 13.0.1 Summary of How this Proposal Addresses the Problem
> > >
> > > In order to ensure efficient and appropriate use of resources, AFRINIC
> > > shall conduct regular reviews of resource utilisation held by its
> > > members. This would allow recovery of any type of resource, where
> > usage
> > > is not in compliance with the RSA. Those resources can be reallocated
> > > for better usage.
> > >
> > > 13.0.2 Proposal
> > >
> > > The policy proposal will modify the CPM as follows:
> > >
> > > Insert a section 13 to the CPM as follows:
> > >
> > > 13.0 Internet Number Resources Review
> > >
> > > Regular reviews of resource utilisation are conducted by AFRINIC to
> > > ensure efficient and appropriate usage of resources. This allows for
> > > recovery of any type of resource where usage is not in compliance with
> > > the RSA; to allow such resources to be reallocated for better usage.
> > >
> > > 13.1 The reviews shall be based on compliance with the terms
> > outlined in
> > > the RSA and Allocation/Assignment Policies.
> > >
> > > 13.2 The reviews cover all allocated/Assigned resources, but priority
> > > goes to IPv4 and ASN mappable to two-octet ASN.
> > >
> > > 13.3 Classes of review: Members to be reviewed shall be selected
> > > according to the following classes:
> > >
> > > 13.3.1 Random
> > >
> > > The member is chosen by AFRINIC at random between the members who has
> > > not been reviewed for any other reasons in the preceding 24 months.
> > >
> > >
> > > 13.3.2 Selected
> > >
> > > Member is selected because of an internal report or due to a lack of
> > > contact between the AFRINIC and the member.
> > >
> > > 13.3.3 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.
> > >
> > > AFRINIC staff may, at its sole discretion, after having assessed the
> > > nature of the evidence found in the community complaint, require that
> > > such evidence be (i) submitted in the form of a sworn affidavit or
> > (ii)
> > > declared to be true before a Commissioner of Oath.
> > >
> > > 13.4 In case of non-compliance and if evidence has been established in
> > > accordance with:
> > >
> > > • Breach of AFRINIC policies
> > > • Breach of the provisions of the registration service agreement or
> > > other legal agreements between the organisation holding the
> > resource and
> > > AFRINIC.
> > >
> > > AFRNIC shall initiate the resource recovery process on the portion of
> > > addresses found to be noncompliant.
> > >
> > > A) AFRINIC shall attempt to contact the organisation and correct any
> > > discrepancy towards the RSA. Except in cases of fraudulent resource
> > > acquisition or unlawful usage and abuse, the organization shall be
> > > given a minimum of six(6) months to effect the return of the
> > resources.
> > >
> > > If the organisation is cooperative and working in good faith to
> > > substantially restore compliance or has a valid need for
> > additional time
> > > to renumber out of the affected blocks, AFRINIC shall negotiate a
> > longer
> > > term.
> > >
> > > The acceptance level of compliance and duration of the longer term are
> > > at AFRINIC staff discretion.
> > >
> > > B) If the situation cannot be rectified and the member did not
> > transfer
> > > the resources to meet other AFRINIC-approved needs as per adopted
> > policies
> > >
> > > AFRINIC shall publish the resources to be recovered for a period of
> > > three (3) months; during which the organisation may at any time, seek
> > > compliance or transfer the resources to other members
> > >
> > > After this period, the resource shall be recovered and therefore the
> > > records of the previous holder of the recovered resource shall be
> > > updated in AFRINIC’s databases.
> > >
> > > C) Any Internet Number Resources recovered under this policy may be
> > > assigned/allocated under existing Allocation and Assignment Policies.
> > >
> > > 13.5 Appeal procedure
> > >
> > > Reviewed members who are not satisfied have the right to appeal
> > against
> > > the results on the review within the four weeks following
> > communication
> > > of the results by AFRINIC. Appeals shall follow an arbitration process
> > > as provided for in the
> > > Code de Procedure Civile (Code of Civil Procedure) of the Republic of
> > > Mauritius. AFRINIC may, on request from an aggrieved party, suggest a
> > > pool of arbitrators who shall be knowledgeable volunteers from the
> > > community.
> > >
> > > 13.6 Compliance Report
> > >
> > > AFRINIC shall publish an annual meaningful report describing review
> > > activities, in accordance with all applicable laws and regulations.
> > >
> > > 13.7 Acknowledgements
> > >
> > > The authors thank Ms Wafa Dahmani Zaafouri (become Afrinic GC
> > Chair), Mr
> > > Serge ILUNGA (become Afrinic Board member) and Mr Alain P. Aina for
> > > their contributions in the development of this Policy proposal.
> > >
> > > The authors also thank the community for the discussions and
> > contributions.
> > >
> > > 4.0 Revision History
> > >
> > > 18 May 2016
> > > Version 1.0
> > > - First Draft AFPUB-2016-GEN-001-DRAFT01
> > > - Posted on RPD list
> > >
> > > 05 Aug 2016
> > > Version 2.0
> > > - Second Draft AFPUB-2016-GEN-001-DRAFT02
> > > - Change on the policy’s name
> > > - Addition of the Acknowledgement section
> > > - Rephrasing of section 3.3.3
> > >
> > > 18 Nov 2016
> > > Version 3.0
> > > - Third Draft AFPUB-2016-GEN-001-DRAFT03
> > > - Update of section 3.3.3 from discussions on mailing list
> > > - Update of section 3.7 (Acknowledgements) to thank the community for
> > > discussions and contributions
> > >
> > > 11 Apr 2017
> > > Version 4.0
> > > - Fourth Draft AFPUB-2016-GEN-001-DRAFT04
> > > - Update and Rephrasing of section 3.4
> > > - Update and Rephrasing of section 3.5
> > > - Update and Rephrasing of section 3.6
> > >
> > > 21 Oct. 2107
> > > Version 5.0
> > > - Fifth Draft AFPUB-2016-GEN-001-DRAFT05
> > > - Adding the paragraph C to 13.3.3. according to the legal counsel
> > > proposition
> > > - Rephrasing the paragraph 13.5 to comply with staff and legal
> > assessment
> > > - Rephrasing the paragraph 13.6 to comply with staff assessment and
> > > avoid any ambiguity
> > > - Changing the co-authors list
> > > - Updating the Acknowledgement session
> > > - Amending 13.4 (B) to reflect the Transfer policies
> > >
> > > 06 Apr. 2018
> > > Version 6.0
> > > - Sixth Draft AFPUB-2016-GEN-001-DRAFT06
> > > - Removing categorisation between membership in random class
> > section 13.3.1
> > >
> > > 06 Apr. 2019
> > > Version 07
> > > - Seventh Draft AFPUB-2016-GEN-001-DRAFT07
> > > - Modifying section 13.4 Paragraph A) to clarify the resources
> > recovery
> > > process: set conditions under which a member could be given
> > longer term
> > > to effect the return of affected resources.
> > >
> > > 29 may. 2019
> > > Version 08
> > > - Eighth Draft AFPUB-2016-GEN-001-DRAFT08
> > > - Section 13.3.1 changes to : "..The member is chosen by AFRINIC at
> > > random between the members who has not been reviewed for any other
> > > reasons in the preceding 24 months."
> > > - Section 13.4 last paragraph changes to : "AFRINIC shall initiate
> > > ... on the portion of addresses found to be noncompliant."
> > > - Section 13.5 changes to “Reviewed members who are not satisfied
> > > have the right to appeal against the results on the review within the
> > > four weeks following communication of the results by AFRINIC……..”
> > > - Typos and grammatical errors fixed.
> > >
> > -------------------------------------------------------------------------------
> > > End
> > >
> > ---------------------------------------------------------------------------------
> > >
> > >
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