Public Comment is a vital part of our multistakeholder model. It provides a mechanism for stakeholders to have their opinions and recommendations formally and publicly documented. It is an opportunity for the ICANN community to effect change and improve policies and operations.
We welcome the work of ICANN on releasing the document in line with Workstream 2 Recommendations on ICANN Transparency. Our analysis shows that, primarily, the document is a good first step but has fundamental gaps in ensuring the full implementation of Section 27.2 of the ICANN Bylaws (on Human Rights) and other Bylaws that have an impact on human rights.
CCWP-HR therefore implores ICANN to consider the recommendations below, which would ensure that the Pilot Holistic Review is implemented more closely with international law and best practice.