Thanks Ginny, Larry, Peter, and some others who replied off-list.

So I understand that in 2015 people are much less at liberty to say "this 
is what we do" in a public forum than, say, 20 years ago. So I'll ask 
generally, maybe even hypothetically:

Third party: There will be clear cut instances wherein a contracted third 
party is maintaining the client's records on the client's behalf. And, 
conversely,  there will be clear cut cases wherein the third party's 
records of their contracted service are their own - contract, 
correspondence, project documents - and do not belong to their client.  2 
Questions:

1. Is there language/criteria that one might use for less clear cut cases 
that will set the standard for delineating whether or not the third party 
is maintaining records that belong to the client? 

2. What might one do in the case were the third party receives a complete 
duplicate of a set of records but the client still maintains the primary 
copy? Will the third party still be held to the clients standards of 
records retention? (separate from data protection).

Thanks,
Gary




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