On Thu, 21 May 2026, Jaroslaw Rafa via mailop wrote:
Considering end user's IP address to be PII is a stupid law in my opinion,
but such a stupid definition has been introduced here in Europe by GDPR:
"‘personal data’ means 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;"
Many lawyers argue that "online identifier" mentioned in that definition
includes an IP address.
Our Polish data protection law that was in effect before GDPR was adopted
had a better definition IMHO, because it said that personal data is data
that allow to identify a person *without excessive effort*. If you have
person's name or street address, then you can identify that person quite
easily - so that has been considered personal data. But to identify a person
based eg. on a car registration number requires excessive effort, because
you have to involve the police or some government office that has access to
registration numbers database. Similarly, identifying a person based on IP
address requires excessive effort, because you have to involve the ISP
owning the network range in question. So that was not considered personal
data.
But GDPR does not have the clause of "excessive effort", so under GDPR
everything that gives even slightest possibility to identify a person (even
if it would require detective work ;)) can be considered personal data. That
is simply stupid IMHO.
I'm getting off topic for the list, but if you want to protect people
from detectives the GDPR definition is *not* stupid.
I do not consider protecting people from detectives to be wrong in all
cases, since there are bad detectives.
--
Andrew C. Aitchison Kendal, UK
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