IP address is personal data

I saw this article in my LinkedIn feed (Sebnem Erener) voiced her opinion on this.

IP address IS personal data. Identification does not only mean the name, address, location of a person but also potential identifiability, linkability and inference. Any information that is useful in tandem with other data points to identify individuals is personal data. Account must be given to all the means likely reasonably to be used for identification, paying attention to the current state of technology. In other words, if it would not take disproportionate effort to (re)identify a person it is personal data and must be protected, including IP addresses. This is not only based on the interpretation of the GDPR but has been established by ISO, Article 29 WP and ECJ previously.

Just to give my 2-cents to Sebnem’s LinkedIn post. Outside of the technical side, given that 20 years of my career have been in IT and security, I understand why he thinks how he does, but he is nonetheless wrong!

Take just 2 of his arguments of why the IP address is not personal data in his ‘non-so-humble’ opinion 😉

According to the article: An IP address is not personal to an individual. It is a shared piece of data. Some might argue that you can use IP addresses for tracking and targeting, but the truth is, they really are only useful in tandem with other data points.

Sorry but personal data is any data linked directly or indirectly to a natural person. See the linkability mentioned in Sebnem’s post.

Then we move on to another argument:

According to the article: Article 17 of GDPR, the Right to Erasure (“right to be forgotten”), states that anyone in the EU can request that a website delete all of their personal data, including records that correspond to their IP address………Why would someone need an IP address “forgotten?” 

Clearly the author is oblivious to the fact that the data subject does not have an ‘absolute right’ neither the concept of ‘legitimate interest’.


Swedish utgivningsbevis is still in force

It has been interesting watching the action now being made to claim the rights of the data subject as stipulated in the GDPR. On average there seems to be for the larger businesses around 10 SARs requests, although, to say on average is not correct in that we are only one month into the aftermath of the GDPR 🙂

I was delighted to see Lucas Khan in action, claiming to have his personal data removed from public sources in Sweden which is the product of something called an utgivningsbevis issued in the name of freedom of speech. I wrote loads on this since already, and its great to have some company 🙂

btw. this will be fixed with the e-Privacy Regulation. I’ll dig out the quote later in another post.

Some of the posts:

Personal data is still PUBLIC in Sweden!

Personal data still public and for sale in Sweden!

Sweden is going to have fun with the new Data Protection Regulation

Ratsit is so kind as to remove sensitive data from public eyes

There is more. Just search 🙂