Scenario An online retailer collects personally identifiable and private information about its customers, including their names, addresses, email addresses, cell phone numbers, birthdates, credit card information and “rewards points” account numbers for hotels and airlines. The retailer recently received a document request for “all information collected about each of your customers.” The retailer’s General Counsel is concerned not only about whether some or all of the information will be required to be produced, but also about how to protect the privacy rights of its customers in the event that production of the personal information is ordered.

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