[AusNOG] Data Retention - are you kidding me??

[Paul Brooks]

On 22/11/2016 3:27 PM, David Beveridge wrote:
> https://www.ag.gov.au/NationalSecurity/DataRetention/Documents/Dataset.pdf
>
> 2. The source of a communication 
> Identifiers of a related account, service or device from which a communication has
> been sent or attempted to be sent by means of the relevant service.
>
> Identifiers for the source of a communication may include, but are not limited to: 
> • the phone number, IMSI, IMEI from which a call or SMS was made 
> • identifying details (such as username, address, number) of the account, service or
> device from which a text, voice, or multi-media communication was made (examples
> include email, Voice over IP (VoIP), instant message Topic Description of
> information Explanation or video communication) 
> *• the IP address and port number allocated to the subscriber or device connected to
> the internet at the time of the communication, or *
> • any other service or device identifier known to the provider that uniquely
> identifies the source of the communication.***In all instances, the identifiers
> retained to identify the source of the communication are the ones relevant to, or
> used in, the operation of the particular service in question.*

The question is about email application and email communications. Retaining the
addressing information at the level of 'email application service'. The CAC and AGs
have confirmed there is no requirement to retain addressing information at a different
'layer' than the service under question.
TCP port numbers do not need to be retained for retaining information about emails and
an email service. Nor ethernet MAC addresses or ATM cell IDs if thats the way you
roll. Only identifiers relevent to the service under consideration - e.g. email
addresses, and potentially email server DNS names if you provide specific names to
your customers as part of your service definition.

Note you aren't breaking any law by voluntarily providing port address information if
you have it - nothing in the legislation says you can't provide additional information
voluntarily. But you don't need to, for an email application service.



>
> On Tue, Nov 22, 2016 at 2:14 PM, Paul Brooks <paul.brooks at tridentsc.com.au
> <mailto:paul.brooks at tridentsc.com.au>> wrote:
>
>     On 22/11/2016 2:52 PM, David Beveridge wrote:
>>     Pretty sure you're also meant to be keeping the source and destination tcp
>>     ports as well which weren't there.
>>
>>     dave
>
>     Why?  why would you need to?
>
>
>>
>>     On Tue, Nov 22, 2016 at 1:49 PM, <russell at central-data.net
>>     <mailto:russell at central-data.net>> wrote:
>>
>>         Yes you are correct you should not be keeping record of the Subject line
>>         and i should have made it clear to strip it out when transporting the logs.
>>         Thanks for catching it though and ensuring people are clear on it
>>         Most systems will have the subject line in their standard logs and can
>>         simply be stripped out later \ not collected at all when sending over to
>>         data retention.
>>
>>         Its a pretty fine line to collect all of the "relevant" data while not
>>         infringing on the privacy laws
>>
>>
>>         Kind Regards,
>>
>>         Russell Brooks
>>
>>
>>         Central Data Systems Pty Ltd
>>         88 Havelock Street, West Perth, WA 6005
>>         Phone: 08 9481 4010
>>
>>         www.central-data.net <http://www.central-data.net>
>>
>>         -----
>>
>
>
>     Paul
>
>


-- 

*Paul Brooks*

*Executive GM - Networks & Technology*

Email: paul.brooks at tridentsc.com.au

Mobile +61 414 366 605

 

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*Trident Subsea Cable Pty Ltd*

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