Good evening:
Thankyou, Stephanie, for these interesting observations, with which I largely concur. I am also not a lawyer, but as a long-standing participant in ICANN processes, may I observe that these matters have been under discussion for nigh on fifteen years.
1. There is no call for any further public consultation and delay. That has been done. All the relevant information is already available:
either through past consultation and communication, or through a review of applicable laws.
2. The primary objective should be for ICANN to align its privacy policy on global best practice. That is not the case today.
3. Failing which, and meanwhile, ICANN should institute 'block-exemptions' to allow Registries and Registrars to automatically conform a priori - in their accreditation contracts - to
the privacy laws of their jurisdiction.
Obviously it is unnecessary and undesirable to attempt to customise case-by-case each accreditation agreement, whereas the generally applicable privacy laws are already known.
The costs of such customisation to ICANN and to the Registries and Registrars concerned are unjustified.
Best regards
CW