Subject: AW: [Enum] Compendium on enumservices registration

From: "Stastny Richard" <[email-masked]>
Date: Thu, 21 Nov 2002 07:56:01 +0100

-----Ursprüngliche Nachricht----- 
	Von: Eric Brunner-Williams in Portland Maine [mailto:[email-masked]] 
	Gesendet: Mi 20.11.2002 18:40 
	An: Stastny Richard 
	Cc: [email-masked]; [email-masked] 
	Betreff: Re: [Enum] Compendium on enumservices registration 

	Richard,
	
	> BTW, I will not have any problem putting my name, e-mail address and
	> even may street address in ENUM, because the same information is
	> in listed in the phone directory (public on the Internet).
	> And this information can be retrieved also by number.
	
	Could you do me a favor and explain what this means to you?
	
	Opinion 5/2000 on The Use of Public Directories for Reverse or
	Multi-criteria Searching Services (Reverse Directories)
	
	The url (auf deutsch) is
	http://europa.eu.int/comm/internal_market/en/dataprot/wpdocs/wp33de.pdf
	
	Eric
	Thanka for the German link, but I am quoting now from the English version;-)

	Of course we know of these (and other EU documents) and currently our legal department is developing the information necessary to be given to the subscriber and be accepted by him for ENUM (together with the regulator).

	Citations from the document you mentioned:

	... to what is necessary to identify a particular subscriber, unless the subscriber has given his unambiguous consent to the publication of additional personal data".

	----

	However, reverse searches can prove useful and should not be prohibited as such. With a view to making such processing fair and lawful, the conditions of the Directives have to be complied with:

	Since the use of personal data in public directories for reverse or multi-criteria searching services is a new purpose, the data controllers have to inform the data subjects about it (Articles 10 and 11 of Directive 95/46/EC).

	end of cittations

	You will also now, that DNS is NOT a directory service in the common sense, so it cannot be used by the mentioned multi-criteria searching services.

	May I also draw your attention  to the footnote 1 on page 3:

	The representatives of the Austrian, Danish, and Portuguese Data Protection Authorities expressed their view that in their countries the practices of reverse searches have not led to specific problems so far.

	And as far as Austria is concerned, we are offering in principle the same service with is available if you call up the directory service and ask for the name for a given phone number. And I also know, that this is an absolute NONO in Germany and UK.

	My conclusion is, that IETF is a protocol body and not a national regulator. If it is not allowed in Germany to put the name in, fine. If it is allowed in Austria, also fine. Where is the problem? Thats exactly why we have national ENUM forum and platforms, and one of the main tasks is to develop with the regulator a policy framework according to the laws in this country.  This is IMHO not the task of IETF to act as super regulator (one ITU-T and one European Commission  is enough.

	best regards

	Richard

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---

From: Eric Brunner-Williams in Portland Maine <[email-masked]>
Date: Thu, 21 Nov 2002 07:18:00 -0500

Richard,

Thanks for quoting the English version.

> You will also now, that DNS is NOT a directory service in the common sense,
> so it cannot be used by the mentioned multi-criteria searching services.

I honestly don'k know what the authors ment by "directory service". It seems
possible that they ment exact match as well as inexact match semantics, and
didn't distinguish between distributed loose, converging consistency, and
centralized store for repository state. The dig tool makes queries for more
than one type of record.

I can't speak to the author's intent, nor to how the language of this document
is correctly applied to our context. Having met several of the authors, I do
have the sense that they do have some views on the applicability of their work
to the DNS.

> My conclusion is, that IETF is a protocol body and not a national regulator.
> If it is not allowed in Germany to put the name in, fine. If it is allowed 
> in Austria, also fine. Where is the problem?

In my view the protocol problem is to create mechanism(s) that allow the
application of policies. These may be cost-recovery policies, or policy
based processing algorithms, or access controls, etc.

Borrowing the "internationalization" -- > "i18n", "localization" --> "l10n"
convention, this is "jurisdictionalization" , or j19n.

What, if any, are the j19n considerations of some protocol, e.g., dns in the
service of enum, seems to be the question at hand.

> Thats exactly why we have national ENUM forum and platforms, and one of the
> main tasks is to develop with the regulator a policy framework according to
> the laws in this country.

I can't speak to that, but to the degree that national jurisdictions have
policy scope, it seems reasonable to treat them as any other form of policy.

I'm aware that the rational has been offered that the value of consistency 
is greater than the value of national jurisdiction for the dns.

I don't find the claim particularly compelling, but exists.

I'm only interested in mechanisms to allow j19n. I take for granted that some
jurisdiction has a policy it would like to deploy.

Eric