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
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-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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