For all those who think they can allow others to hold the records.
http://www.usdoj.gov/opa/pr/2005/May/05_ag_272.htm
http://edition.cnn.com/2005/US/05/17...egs/index.html
So if you're in the US the rules just changed. If you don't have the IDs, take down the content.
Sorry to give you the bad news.