What is Personal Data (GDRP)?

The text of the GDPR defines Personal Data as:

“Any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;”

For practical reasons, we are defining two levels of personal data within CWIE.  Tier-1 data is considered personal in and of itself.  Tier-2 data is considered personal when it is stored in conjunction with (combined, or alongside) tier-1 data.

Tier-1 personal data (i.e. data that can/should be considered to be personal all by itself) includes:

  • First and Last Name
  • National ID / Passport Number / Driver’s License
  • National Insurance Number / Social Security Number / Tax Number
  • Personal E-Mail Address
  • Landline Number / Mobile Number
  • Bank Account Number / Credit Card Number / BIC / SWIFT

Tier-2 personal data items are probably too numerous to list (since they will grow over time as technology expands its reach) but I’ll drop a few to give an idea of what we’re talking about:

  • IP Addresses
  • MAC Address
  • Web Cookies
  • Session Data (including Session ID’s)
  • RFID Data (i.e. Tags)
  • Audit Trail / Logs (that may contain one or more of the above mentioned Tier-2 data within them)
  • Location / GPS data
  • Personal Address (Includes home address and/or billing address - Address Line 1, Address Line 2, Apartment Number, City/Town Name, Post Code, Country)
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