zlacker

This is like saying every physical business is collecting PII because employees can technically take a photo of a customer. It's hard to do business without the possibility of collecting PII.

>>charci+(OP)
No, it's like saying a business that has a CCTV camera recording customers, and sending that data off site to a central location, where they proceed to proceed to use the data for some non-PII-related purpose (maybe they're tracking where in stores people walk, on average), are in fact sending PII to that off site location.

Distinguishing factors from your example include

1. PII is actually encoded and handled by computer systems, not the mere capability for that to occur.

2. PII is actually sent off site, not merely able to be sent off site.

3. It doesn't assert that the PII is collected, which could imply storage, it merely asserts that it is sent as my original post does. We don't know whether or not it is stored after being received and processed.

>>gpm+6g
I was giving a purely physical, analog example.

>>charci+nK
If you imagine the CCTV camera in my example is a film-video-camera and the processing happening off site is happening in a dark room and not on a computer... my more accurate version of your analogy is also analog.