Netnod comments on the Data Retention Directive in Sweden

Full details of the comments on the proposed adjustments can be found in Swedish in the document link below. The following is a summary of Netnod's main comments:

1. Netnod does not believe that this investigation has fully addressed the issues related to data retention, the causes and what mitigation methods might exist. For example, Netnod believes the proposed implementation of the directive should be investigated together with other related regulatory changes. For example what potential impact might Swedish ratification and implementation of the Council of Europe Cybercrime Convention have on MLATs which in turn might impact the need for extended data retention. 

2. Netnod does not believe that the suggestion to store more data than IP addresses should be carried out. Storing more data, for example port numbers used in a carrier grade NAT, have impact on integrity and is problematic both technically and operationally. Carrier Grade NAT and other mechanisms have negative impact on Internet Access in general and Netnod believes instead that the issues that leads to CGN deployment should be addressed. For example the lack of IPv6 deployment.

For further details see the full response (in Swedish).