1. The down side is that it cannot be used across the clients even for the same user
2. Using the same encryption key was a bad choice here, a per user key would have solved this issue for sure.
> a per user key would have solved this issue for sure
It would have helped with PII leakage, but not with plain-text trace extraction attacks, right?
The compliance rules at times are outdated and people skirt around them by following the worded rule instead of the intent.