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Originally Posted by GatorB
Oh I think that's an issue too. The DOJ will say "Why don't YOU have the key? YOU are the custodian of records."
Say you promote 20 sponsors and all 20 had such a system. Is the DOJ willing to wait for you to call to get 20 keys? And what if you couldn't get anyone on the phone?
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What if you have 30-40 people on staff, I can't imagine every employee would have access to the key. If I was a large company (like a sponsor for example), I'd have the actual records (paper versions) kept in an actual safe and have my attorney keep the key. That way when an audit happens, my attorney will be present. I think providing the actual database of encrypted records should suffice as possession of the records. While its not immediately viewable, it should be enough in my humble opinion. Whether this stands true in a court has not been determined, but its much better than the existing solution proposed by TCG in my opinion.
WG