Law360, New York ( June 18, 2014, 10:15 PM EDT) -- Scenario: A large organization is selling one of its business units. Questions arise about how to define the scope of data associated with employees in the business unit being sold that may need to be transferred to the new owner and whether to implement a process for remediating "custodial" data associated with those same soon-to-be-departing employees. As part of this process, the organization is attempting to compile records identifying all current and former employees associated with the business unit, including any "custodial" data associated with those employees and any employees on legal hold. The organization does not have an identity management system that would help track data associated with those employees. The general counsel's office is working with the compliance and and information technology departments to determine how to compile the necessary information....
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