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Comment by ericpauley | Hacker News Reader

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ericpauley·

In that case the database is the PII, not the IP.

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If Person A has a document saying that Joe Biden lives at 1600 Pennsylvania Avenue

and Person B has a document saying an 80 year old male living at 1600 Pennsylvania Avenue has Chlamydia

do you think only Person A holds private information?

Users use the same passwords everywhere. By cross-referencing user passwords through excessive brute force you could find accounts on other sites that link to a user’s personal data.

Is the password personal data?

You have to draw the line of correlation difficultly somewhere.

I would expect a company to guard customers' passwords every bit as carefully as they guard customers' e-mail addresses, and probably moreso, yes.

The term "personally identifiable information" does not occur anywhere within the text of GDPR. GDPR regulates the use of personal data, which is conceptually much broader than PII. Any data that relates to a natural living person is potentially within the scope of GDPR, including data that is insufficient in isolation to identify a natural living person. For example, pseudonymised data from an employee database or medical records may still constitute personal data if it would be possible to reconstruct the identity of that individual by inference, even if all direct identifiers have been removed.

https://commission.europa.eu/law/law-topic/data-protection/r...

So someone can be identified, directly or indirectly, with an IP address, making it personal data under GDPR, art. 4(1).

What does "indirectly" include legally?

Any piece of information that can be related to someone using supplementary information. Eg. My personnal email address contains my name, so I can be identified direclty; my phone number doesn’t, but my operator and contacts knows who is behind it, so I can be identified indirectly.

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