Andreas Fink afink@list.fink.org wrote:
The technical document does not specify which information to be stored. That's the point. The law says "Verbindungs und Abrechungsdaten". However what is connection data?
In my opinion, based on carefully reading the relevant definitions in the law on telecommunication (Fernmeldegesetz, FMG), "connection data" in the context of ADSL should be understood as referring to the connection between the ADSL modem and the DSLAM, and *not* as referring to anything done by means of TCP connections or anything else at such high layers in the OSI reference model.
From their letter, I expect that ISC-EJPD PFÜ probably disagrees with
me regarding this point, and in fact I believe that they're currently engaged in reinterpreting the law with the goal of pretending that it says what they want it to say, even if it actually doesn't.
SIUG has initiated correspondence with ISC-EJPD PFÜ aimed at getting them to formulate a clear position about what in their opinion is the precise meaning of the term "Fernmeldedienst" to which these "Verbindungs und Abrechungsdaten" are supposed to refer.
I'll post here as soon as we have results from this (either a clear answer or enough failed attempts to get them to answer that it's clear that they're dodging the issue). At that stage it will be time to discuss how to best get the parliament involved.
Greetings, Norbert
P.S. Is someone here interested in joining SIUG's "core group" and actively contributing in SIUG's work on this issue?