When it comes to the needs of U.S. business, the United States has been, and will continue to be, very vocal. Our online licensees need to know that this Directive also impacts information collected offline. Companies with a physical presence in Europe, or with a server in Europe, need to apply the directive to any human resources data. Each company needs to take stock of its own level of risk and liability. For example, a company with a presence or a server in Europe has greater risk of being impacted by the provisions of the Directive.
Companies based solely in the United States have a lower level of risk.
Our licensees must do a self-assessment to find out if and how they are collecting data from European citizens. Currently, a lot of the discussion between the European Union and the United States is focusing on the transfer of offline data. When the law was written, the Internet wasn't as strong as it is now. There's no precedent yet about how Internet companies should implement the Directive. On behalf of our licensees, we are in almost daily contact with the decision-makers in Washington.