My read of Bill C-11 is different than yours.
In the section entitled "Provisions Respecting Providers of Network Services or Information Location Tools", the Act states:
41.26 (1) A person described in paragraph 41.25(1)(a) or (b) who receives a notice of claimed infringement that complies with subsection 41.25(2) shall, on being paid any fee that the person has lawfully charged for doing so,
(a) as soon as feasible forward the notice electronically to the person to whom the electronic location identified by the location data specified in the notice belongs and inform the claimant of its forwarding or, if applicable, of the reason why it was not possible to forward it; and
(b) retain records that will allow the identity of the person to whom the electronic location belongs to be determined, and do so for six months beginning on the day on which the notice of claimed infringement is received or, if the claimant commences proceedings relating to the claimed infringement and so notifies the person before the end of those six months, for one year after the day on which the person receives the notice of claimed infringement.
My take is that you need to hang onto records for a specific claim of infringement for a period of 6-12 month ONLY once you've received notice about that specific claim.
In other words, you can operate as you do today (30 days) but need to 'archive' the alleged infringer's IP info for 6-12 months once notified, ie. do a SQL 'select' on the offending IP and insert those results into an 'AllegedInfringers' table -- with triggers to automatically delete the data after the requisite period of time ...with automatic daily purges of "AllegedInfringers' table backups
I stand to be corrected on my interpretation of C-11, or if there's any other in-force legislation which requires you to retain logs for longer than zero (0) days.
Sure.. we're keeping logs for 90 days.
If and when a new law comes into effect (it's not in effect now), we'll do what we have to do under the law.
I dont want to be dismissive about such important things. I do want to make it clear that I dont plan on spending my days in exchanges of legal matters.. of any kind.. regulatory or otherwise. I want to spend my days trying to help people get great internet access and great support...
Marc - CEO/TekSavvy