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It's important to note that only IP adresses in combination with a timestamp are considered personal data under GDPR.
by c3tru 8y ago
It's important to note that only IP adresses in combination with a timestamp are considered personal data under GDPR.
- Matticus_Rex 8y agoCitation? That wasn't mentioned in the WP29 draft guidance I read.
- c3tru 8y agohttp://curia.europa.eu/juris/document/document.jsf?text=&docid=184668&pageIndex=0&doclang=en http://curia.europa.eu/juris/document/document.jsf?text=&doc... That's the detailed version of the ruling. The ruling refers to IP adresses with time and date, as explained in point 37.
- Buge 8y agoIt says IP address and time are necessary for it to be personal data, but not sufficient. To be personal data you also have to have access to some mapping to map those back to actual people. For example if you have an agreement with ISPs that allows you to map IP+time to person, then the IP+time is personal data. In the absence of such agreement, it isn't necessarily personal data.
- c3tru 8y agoYou do not need access to the mapping. It's only important if such a mapping is possible.
- apple4ever 8y agoNo access important. Mapping is possible only with access. So IPs and time stamps are not PII by themselves.
- Buge 8y agoIt says access to the mapping is required. Point 49. >a dynamic IP address registered by an online media services provider [...] constitutes personal data within the meaning of that provision, in relation to that provider, where the latter has the legal means which enable it to identify the data subject with additional data which the internet service provider has about that person.
- Matticus_Rex 8y agoThe EU is a civil law system, and that's not what regulators are saying now, so that does nothing for us.
- c3tru 8y agoCan you elaborate this? How has an european judgment to the definition of personal data nothing to do with the GDPR?
- Matticus_Rex 8y agoIn the US, we have a common law system, so a court ruling about the meaning of something instructs regulators on the interpretation of what the law means going forward. In a civil law system, judicial interpretation doesn't control how the law is interpreted by regulators.