The WG recommends that as part of the implementation process due consideration is given to potential privacy issues that may arise from the discussions on the transition from thin to thick Whois, including, for example, guidance on how the long-standing contractual requirement that registrars give notice to, and obtain consent, from each registrant for uses of any personally identifiable data submitted by the registrant should apply to registrations involved in the transition. Should any privacy issues emerge from these transition discussions that were not anticipated by the WG and which would require additional policy consideration, the Implementation Review Team is expected to notify the GNSO Council of these so that appropriate action can be taken.  

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The WG recommends that following the adoption of this report and recommendations by the GNSO Council, the subsequent public comment forum (prior to Board consideration) as well as the notification by the ICANN Board to the GAC, specifically requests input on any considerations related to the transition from thin to thick Whois that would need to be taken into account as part of the implementation process. 

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