As geoTLD group we have made, among many other parties from the ICANN community, a comment towards the Hamilton Legal Analysis Part 3. All of the comments made are collected and published at Legal Analyses, Proposed Compliance Models, & Community Feedback.
Our comment is:
Dear ICANN Team,
Please receive the comment from the geoTLD.group on the “Layered Access Approach” described in Part 3 of the Hamilton legal analysis. The geoTLD.group thinks that a Layered Access Approach or Tiered Access, which will allow protecting private data from public view while making it available to Authorised Parties, is a relevant solution to GDPR in our industry. We view the definition of Authorised Parties as an issue to be resolved and welcome community input on the matter.
GeoTLD Group Chair
More information is given at our internal site a http://geotld.group/gdpr