This article makes a compelling argument that it could be: http://privacylawblog.fieldfisher.com/2016/can-a-dynamic-ip-address-constitute-personal-data/ http://

This article makes a compelling argument that it could be: http://privacylawblog.fieldfisher.com/2016/can-a-dynamic-ip-address-constitute-personal-data/ http://privacylawblog.fieldfisher.com/2016/can-a-dynamic-ip-... IANAL, but I'd be wary of saying that you'll be fine storing dynamic IP addresses. You'll probably need to have a rationale as to why you don't consider it.