Taskforce EMC2 email list archives


Subject Re: What is personal identifiable data - in your country?
From David Simonsen <david@xxxxxxx>
Date Wed, 30 Sep 2009 11:34:00 +0200

Hello all, sorry for only returning this late in the conversation.

On Sep 25, 2009, at 3:29 PM, Peter Schober wrote:
* David Simonsen <david@xxxxxxx> [2009-09-25 14:55]:
The DK version is: ALL data is personal identifiable data.
Yes, this is right(!): IP-adresses, roles... - anything!
The argument is that it _may_ be related to a person, IF you (aka God)
get a chance to interconnect all (nessecary) data sources.

Have you looked at 95/46/EC?

Yep.

More to the point, the archives of this list should should have
reports from Andrew to that regard (i.e. the one concerned with
pseudonymous identifiers, which also refers to the current
juristiction wrt the status of IP-adresses. You may know that there
have been contradicting rulings from two german courts.)

Exactly - there seems to little consensus on the practical (read: national), even with 95/46 in place, hence my interest in how this is interpreted in the various countries.

AFAIR the possibility of interconnecting pieces to identity a person
also differ whether you can do this on your own (i.e. with info
available from inside your organisation/legal entity; "directly
person-related" would be the translation from the term in Austria), or
if you need cooperation of a third party (e.g. an ISP,
"indirectly ...").

But all this is from blurred memory and IANAL etc.
-peter

Thanks,
David