> Using personal data to assign a cohort counts as using personal data. Duh. The approach described in the article doesn't use any personal data, though? Quoti

> Using personal data to assign a cohort counts as using personal data. Duh. The approach described in the article doesn't use any personal data, though? Quoting the European commission: "Personal data is any information that relates to an identified or identifiable living individual. Different pieces of information, which collected together can lead to the identification of a particular person, also constitute personal data." I'd hazard a guess that it's the second part under which the EC might find this to be within scope.