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[rpd] Publication of Information (Draft-2) - AFPUB-2021-GEN-001-DRAFT02
JORDI PALET MARTINEZ
jordi.palet at consulintel.es
Tue Nov 16 09:19:29 UTC 2021
Responding below, in-line.
El 15/11/21 8:26, "Anthony Ubah" <ubah.tonyiyke at gmail.com> escribió:
This is a thoughtful proposal. You might want to revisit the statement in the Summary of the problem.
At the same time, it is understandable that the justification of a request for resources can be confidential as it can provide insights into a business plan to competitors. However, it is also obvious that in the Internet business, time passes very quickly and the need for confidentiality vanishes very quickly. It is difficult to believe, for example, that you request resources for the next 5 years, and only in year 5, your business will be public.
I find this section very confusing. Can you explain to me how in "Internet business, time passes very quickly and the need for confidentiality vanishes very quickly"?
While the use of Number resources may not necessarily be guarded like the secrets of the coca cola formula, but not less guarded if it is key to a business' private strategy. If resource usage is tied to the initial justification as confidential, then it might be impossible to determine otherwise later, using the algorithm of this proposal or any other text to change that in the CPM.
Resource request justification is well within the gray areas , and we don't want to cast a shadow on it in the name of, "openness, transparency, and fairness".
[Jordi] I disagree. You need number resources because you have or plan to have “n” customers, either in terms of broadband or mobile subscribers, servers in a data center, Cloud services, etc., etc. So, you basically need to “number” things and that means that you can just make always a summary about that justification without compromising any business that may be not yet “public” (which I doubt after 2 years) but at the same time, be transparent enough so the community understands that it is not an artificial justification.
On the proposal, comment inline.
13.0 Publication of Information
Following the principles of openness, transparency, and fairness and considering that we are dealing with community resources that aren’t property, after 2 years of every accepted resource request, the justification of that request must be published.
Why is there a need to publish this justification?
I believe only resources in dispute should be published, and this must only be invoked by a court order. Risks of implementing this include copycat justification and witch hunting from competition.
[Jordi] Again, after 2 years you requested the resources, I fail to see how come publishing a summary can create a trouble for a business. They key here is “summary” not all the information provided to AFRINIC, not a complete network diagram, addressing plan, etc., etc.
The resource member will be warned 3 months before the publication with a draft of the summary to be published. In case there are reasons (such as patents or similar ones), that avoid the publication of those details and demonstrate the unique nature of the services offered which, if disclosed, could damage the resource member business, it will have up to 1 month, to provide an alternative text to be published or request an extension of 1 year on that publication.
Does giving 1 month to provide alternative text give room to provide a different justification, or to revalidate existing justification? How does the additional one year change the privacy status of the business blueprint?
[Jordi] A different justification will break other parts of the CPM/RSA. You’ve got the resources allocated for “something”. If you want to use them for something different, you must reassess the justified need. An alternative text is a way to ensure that if there is a real “business secret” that if disclosed may harm your business, you can agree with the staff in a different way to summarize the information. Very simple. If there is a real secret and the business is not yet public, extending a year, can provide your business a protection against that exposure.
AFRINIC will have 1 month to accept the justification and, in doubt, escalate to the Board that must resolve in a maximum of 1 month after hearing the resource holder.
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.
Please shed more light.
[Jordi] This has been made in all the RIRs many times. You don’t need to implement a policy in such way that you need tons of resources just for one day or week. You can phase it according to your resource availability. It is up to the staff to manage that. We shall try to avoid, unless strictly necessary, micro-management, so this text just explicitly allows the staff to do it.
IPv4 is over
Are you ready for the new Internet ?
The IPv6 Company
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