I'm not sure how the ALAC would wish to deal with this. But quite frankly, it is time ICANN desist from aiding and abetting scofflaws under colour of contract.  And that would be my recommendation for comment.

Simply put, these procedures are intended to assist contracted parties to channel and navigate ignoring their own national privacy laws. 

You might wish to refer the recent EU High Court ruling on privacy in the Safe Harbour context here for guidance.

-Carlton




==============================
Carlton A Samuels
Mobile: 876-818-1799
Strategy, Planning, Governance, Assessment & Turnaround
=============================

On Tue, Oct 6, 2015 at 8:21 AM, ICANN At-Large Staff <staff@atlarge.icann.org> wrote:
Dear All, 

This is to let you know that the Public Comment on the IAG Initial Report and Proposed Revisions to the ICANN Procedure for Whois Conflicts with Privacy Laws has now gone live:  https://www.icann.org/public-comments/iag-whois-conflicts-privacy-2015-10-05-en. 

The dates of the Public Comment will be 5 October 2015 — 17 November 2015 23:59 UTC. During this period, anyone can submit comment via comments-iag-whois-05oct15@icann.org. 

As an advisory committee of ICANN, the ALAC submits Statements on Public Comment and advises on policy matters related to the interest of Internet users worldwide. Not just limited to the 15 ALAC members, members from the wider At-Large community are welcome to draft a Statement on behalf of the ALAC. 

If you are interested in drafting an ALAC Statement on this Public Comment, kindly contact staff@atlarge.icann.org. At-Large Staff will follow up and help you understand the procedure. 

Additionally, the wiki workspace for developing a potential ALAC Statement is here: https://community.icann.org/x/mKNYAw. All pertinent resources for this public comment can also be found there. 

Regards,

Heidi Ullrich, Silvia Vivanco, Ariel Liang, Gisella Gruber, Nathalie Peregrine and Terri Agnew
ICANN Policy Staff in support of ALAC
Twitter: @ICANNAtLarge

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