>> For international retention, we have put considerable effort into finding a "harmonized", reasonable standard for each retention code worldwide.<<

I would be really cautious about using this approach when dealing with consumer/employee PII for EU countries.  While it may be useful when dealing with countries outside the EEA, it would appear to be a significant violation of both the FTC Safe Harbor protections and the legal retention requirements for the specific countries.

Bill Roach, CRM

Opinions are my own and not those of my employer or any other individual or entity.

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