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Subject:
From:
Chris Flynn <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 14 May 2013 09:51:45 -0500
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Always for the best of reasons

Chris Flynn

On Tue, May 14, 2013 at 9:36 AM, Larry Medina <[log in to unmask]>wrote:

> A MUCH broader definition of "personal Info" here....
>
>
> http://www.mondaq.com/unitedstates/x/238392/Data+Protection+Privacy/New+Childrens+Online+Privacy+Protection+Rules+Impose+Heightened+Compliance+Standards+on+Website+and+Software+Application+Operators&email_access=on
>
> http://goo.gl/laLt8
>
> "The new rules also broaden the definition of "personal information" from
> basics such as names and home addresses to include less obvious
> identifiers, such as certain screen names, particular geo-location
> information, audio-visual materials featuring a child's image or voice, and
> some uses of persistent identifiers, such as customer numbers held in
> cookies, selected uses of IP addresses, and certain uses of unique device
> identifiers including those contained in cell phones."
>
> I would assume this would also impact "data at rest"- replicated copies of
> data on servers and/or backups generated that presently include the data in
> question.
>
> It might be advisable for organizations gathering such data to re-examine
> their policies on how long to keep backups (which are intended primarily to
> reconstitute systems in the event of catastrophic losses) and to no longer
> capture fields of data impacted by these changes in backups after July
> 2013.
>
> So many organizations fail to consider data they capture for other purposes
> and how changes of these types may be damaging to them if they fail to
> examine their data gathering practices.
>
> Larry
> [log in to unmask]
> --
> *Lawrence J. Medina
> Danville, CA
> RIM Professional since 1972*
>
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