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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 6 Apr 2011 13:23:52 -0400
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Obviously the "we" in this article is Ireland and I guess a lot of the
answer depends on their interpretation of how this EU directive applies to
them as a member of the European Union.

I haven't read all of the Communications Act, simply because I don't operate
in that environment and it isn't directly applicable to me, but this comment
in the article raises on big question for me:

"The Communications (Retention of Data) Act 2011 was signed into law in
January. The Act requires telephone service providers to retain telephone
data for two years, and internet data to be retained by internet service
providers for 12 months."

How are "telephone data" and "internet data" defined and are the definitions
clear enough that NOTHING in either is subject to any interpretation of what
it applies to?

Also, it says that the 'service providers' must retain it and make it
available to certain parties under certain conditions, but what does "retain
it" require them to do?  

Again, this is similar to other topics discussed in the past where
technology is deployed that is capable of generating incalculable volumes of
"data" that no one has given any thought to how it is going to be managed. 
It seems if you operate as a service provider within the EU, that's no
longer the case... by Law, you MUST find a way to address it.

Larry
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