So your suggestion is that you want to take the bill in hand, go through it, and make the recommendations that you feel are appropriate, or adopt the bill. It's certainly your right to do exactly that.
The discussion paper simply points out specific concerns we've had with it. You can take those comments for what they're worth, use the Information Commissioner's bill, and say, look, this is where we want to go. There's nothing in the mandate that's been given to you that would preclude you from doing exactly that.