Good work on the IBOR draft.
Personally Identifiable Information (PII) should be protected, period. Drop the restriction that it could be used to link data together. PII to include anything that's biometric too, like fingerprints, personal walking gait (yes that's a thing under analysis).
Also please add anti-legalese concept… just today i read that the Verizon TOS is 350+ pages and obscure by design.