[rpd] Publication of Information (Draft-2) - AFPUB-2021-GEN-001-DRAFT02

Sat Nov 13 07:21:28 UTC 2021

Dear Gaby,

Businesses disclose all kinds of information to regulatory authorities all the time e.g local licensing boards. There are legal protections for members against AFRINIC disclosing any content contained in the business plans and other confidential information submitted by members. 

Regards,
Daniel

> On Nov 13, 2021, at 6:47 AM, Gaby Giner <gabyginernetwork at gmail.com> wrote:
> 
> Hi Jordi,
> 
> Thanks for your explanation of the timeframe.
> 
> I am taking the hypothetical stand of businesses that cannot disclose their plans/business out of protecting their interests. It's just that a certain level of privacy is expected esp when a company is starting or making business decisions etc. Disclosing info to AFRINIC in exchange for being allowed resources is like trading in info to a third party that could very well be leaked (let's face it, it happens to corporations/businesses every day). Aside from looking out for traditional corporation privacy pitfalls, they also have to worry about their plans being disclosed to AFRINIC.
> 
> Also, I noticed a logical loop in the proposal. You said "Note also that the policy text provides a way to avoid the publication if justified, or to delay it. So if there is a bussiness that really requires having all the resources up-front, AFRINIC agree on that (following the CPM), and it requires more time and can’t be disclosed to protect the business, it is a very valid justification."
> 
> Then what is the point of the Publication of Information then if all businesses claim that they 1.) require more time, and 2.) they don't want to disclose information? At this point, actually they have disclosed information already to AFRINIC.
> 
> This is a hypothetical situation that is close to reality because I am hard-pressed to find a company willing to give out their business plans to a third party and at risk of their competitors.
> 
> I hope my points are clear.
> 
> Thank you,
> 
> Gaby
> 
> 
> P.S. my other points in the first email were just grammatical stuff but the above is more important, thanks
> 
> 
> 
> On Sat, 13 Nov 2021 at 01:28, JORDI PALET MARTINEZ via RPD <rpd at afrinic.net <mailto:rpd at afrinic.net>> wrote:
> Hi Gaby, all,
> 
>  
> 
> According to existing policies in the CPM, you ask for resources based on justified need.
> 
>  
> 
> If the justified need is not for an “immediate use” (1 year seems reasonable, 2 years may be too much already), then there is no sense that you request those resources in advance, or in fact probably AFRINIC will not allocate them and tell you “come back when you’re ready”.
> 
>  
> 
> I will understand that a LIR that is deploying a big network with no customers yet, will request a smaller prefix and may be, in the case of IPv6, suggest to AFRINIC that they reserve some contiguos space for the next request. Actually this is already the practice in all the RIRs (sparce allocation).
> 
>  
> 
> Note also that the policy text provides a way to avoid the publication if justified, or to delay it. So if there is a bussiness that really requires having all the resources up-front, AFRINIC agree on that (following the CPM), and it requires more time and can’t be disclosed to protect the business, it is a very valid justification.
> 
>  
> 
> Regarding the rewording of my last paragraph, may be a language problem not being native speaker, I fail to see what is not clear, and I believe that the staff understood it correctly looking at the IA of the previous version: https://www.afrinic.net/policy/proposals/2021-gen-001-d1#impact <https://www.afrinic.net/policy/proposals/2021-gen-001-d1#impact>
>  
> 
> What I’m saying is that in every first “2 years anyversary” of each resourse allocation the policy is “executed” and the summary provided and if agreed, published. Also, I’m stating that the implementation may be phased (slow start) by the staff in such way that there is no need to hire more resources. This is needed because otherwise when the policy is initially implemented there is a high demand of human resources to take over “all” those that already surpassed the 2 years.
> 
>  
> 
> I’m not sure to understand your last point.
> 
>  
> 
>  
> 
> Regards,
> 
> Jordi
> 
> @jordipalet
> 
>  
> 
>  
> 
>  
> 
> El 12/11/21 11:41, "Gaby Giner" <gabyginernetwork at gmail.com <mailto:gabyginernetwork at gmail.com>> escribió:
> 
>  
> 
> Hi Jordi, hi everybody,
> 
> Thanks for a quite insightful proposal. However, this type of proactive action (and the details/parameters that you gave) may not translate well into reality.
> 
> Transparency and fairness are important values ofc, given that we operate behind the screen. My concern with the policy would be the parameters that you gave. Do you have a solid statistical basis that says in 2 years, a probable business that asked for resources from AFRINIC would be able to establish their business properly without adverse effects if ever AFRINIC should do as it says in the policy proposal? 
> 
> Secondly, your last paragraph:
> "This policy shall be implemented in such a way that all the resources allocated/assigned for over 2 years, will be chronologically warned, allowing the staff to process the possible responses of “non-disclosure” without requiring extra human resources."
> I'm having trouble understanding this in context with the other content in the proposal. Maybe a rewrite is in order.
> 
> Finally, for the first paragraph, I would suggest that it should be rewritten. On the whole, while transparency is good, I think the execution should be considered carefully.
> 
>  
> 
> Sincerely, Gaby.
> 
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