Hello John
It would be the CPNI non-disclosure rules from the FCC.
WISPA's counsel which does not represent me personally but WISPA as an
organization is and expert on this. He knows the FCC inside and out and has
been warning us about our CPNI requirements for non-disclosure and says
it is not exempted from the small provider exclusion.
His contact information is
Stephen E. Coran
Lerman Senter PLLC
2001 L Street, NW, Suite 400
Washington, DC 20036
202-416-6744 – office
202-669-3288 – mobile
[email protected] – email
www.lermansenter.com
@stevecoran – twitter
IANAL so I can only comment as such. But it does look like an issue.
A law/regulation from the federal government vs an non government
entity contract. It still appears to me that SWIP'ing CPNI information
and displaying it in public WHOIS is a violation of law unless ARIN
has an exemption that would gut the privacy for Internet users.
I guess we could SWIP the IP but put in Customer one and our
POC information.
I am sure Steve can tell page and verse about this.
Thanks you
Take care
Paul McNary
McNary Computer Service
[email protected]
On 7/16/2017 9:38 PM, John Curran wrote:
On 16 Jul 2017, at 8:46 PM, Paul McNary <[email protected]> wrote:
Hello
This is probably targeted to John and the ARIN staff
I was reading some articles today. Under the current net privacy rules and
proposed
net neutrality rule making goes through or even if not, we are not allowed to
put
customer data in a publicly accessible data base. I don't think we are even
allowed
to provide that information to a third party without our customer's written
opt-in.
You can only get the IP "address holder's" information because of the contract
we
have with ARIN where we give up that right of privacy. So you can make us give
you
that information but you can not force us to break the law, if the end user
doesn't have a
contract with ARIN. Even if we would SWIP a current /24 and their information is
disclosed to a third party (ie ARIN) and the end user doesn't have a contract
with
ARIN, I think we are in violation of the Internet privacy rules as they are and
have been.
John, can you and the ARIN staff get a written clarification from FCC about
this.
It basically guts the privacy rule making if SWIP is performed on a customer
who does not give written approval.
What am I missing? The WISPA lawyers say we are still required to follow the
Internet policy rule making.
Paul -
ARIN obviously does not require you “to break the law”, but to be able to further
pursue this matter we’re going to need a bit more information.
Do you have a reference for the particular law or rulemaking proceeding that
the WISPA lawyers assert is in conflict? I would be happy to speak with
them
directly if that would help – email me appropriate contact information
when you
have a moment.
Thanks!
/John
John Curran
President and CEO
ARIN
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