I would reconsider the use of the term “publicly”.
We have chosen to use “publicly” as a way to recognize that if even one person is told, we have to be prepared for the consequences as if the information were shared publicly. Nonetheless your point is well taken. A public announcement by ACM is different, at least potentially, than someone sharing publicly an email that they received from someone representing ACM.
Is this anticipatory of the process taking more than 6 months?
Complaints can, but typically do not, take a long time to get off of the ground. Most typically delays happen when one or more parties to a complaint retain legal representation, there are language barriers that require translation, or gathering information needed to make an informed decision about whether there is sufficient factual evidence to support the allegation. We are hopeful that this is a rare thing, but want to be clear that ACM bears responsibility in informing complainants about progress of their complaints.
The six month requirement in Section 2 refers to complaints that have been taken up as substantial enough to warrant an investigation.
If the complaint is not made by the harmed individual(s), are the harmed individual(s) made aware of the investigation? If so, what happens if they don’t want an investigation? Alternatively, what if the harmed individual(s) assert no harm?
In most cases, harmed individuals are made aware. They essentially become witnesses to the investigation. If they don’t want one, they can refuse to cooperate. ACM may choose to stop an investigation if the harmed individual requests it. The assertion of no harm needs to be taken as a piece of evidence in the case.