That depends – if a specific person can be identified from that email address, then yes (eg. One of the goals when writing the GDPR was to make it more or less timeless: updates to the regulation and the law should not be necessary each And the combination of name and email is an absolutely unique combination globally and therefore an individual can be identified from that data. personal data processed wholly or partly by automated means (that is, information in electronic form); and. Organisations frequently refer to personal data sets as having been ‘anonymised’ when, in fact, this is not the case. This represents good practice under the GDPR. What is personal data? Personal data covers a much broader definition than the previous legislation demanded. For more information please see our guidance on special category data and criminal offence data. Information relating to a deceased person does not constitute personal data and therefore is not subject to the GDPR. Therefore, the firm ensures that the second team can only access the data in a form that makes it not possible to identify the individual couriers. All text content is available under the Open Government Licence v3.0, except where otherwise stated. The members of this second team can only access this pseudonymised information. GDPR defines personal data as: “Personal data is any information relating to an individual, whether it relates to his or her private, professional or public life. In contrast generic business email addresses … The GDPR refers to the processing of these data as ‘special categories of personal data’. The Directive provides, in Article 3, that it applies only to the processing of personal data where the processing is wholly or partly Anonymisation can therefore be a method of limiting your risk and a benefit to data subjects too. Data related to the deceased are not considered personal data in most cases under the GDPR. In order to be truly anonymised under the GDPR, you must strip personal data of sufficient elements that mean the individual can no longer be identified. However, if you could at any point use any reasonably available means to re-identify the individuals to which the data refers, that data will not have been effectively anonymised but will have merely been pseudonymised. In contrast generic business email addresses (e.g. My friend is still only human… most of the time ? The short answer is, yes it is personal data. However, a second team within the organisation also uses the data to optimise the efficiency of the courier fleet. Marketers would therefore need to make a choice between using ‘consent’ or ‘legitimate interest’ for sending electronic communications. If you take my email address, laura.franklin@beswicks.com, it states my full name, as well as the place that I work, clearly identifying me and, therefore, qualifying as personal data. It pseudonymises this data by replacing identifiers (names, job titles, location data and driving history) with a non-identifying equivalent such as a reference number which, on its own, has no meaning. In short, PECR states that you must not send electronic mail marketing to individuals unless: • they have specifically consented, preferably via an opt-in, or • they are an existing customer who has bought a similar product or service from you in the past, and you give them a simple way to opt out of receiving your electronic marketing in every message you send. The GDPR only applies to information which relates to an identifiable living individual. However, you should exercise caution when attempting to anonymise personal data. This also requires a higher level of protection.                   Â. “‘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”. This means that despite your attempt at anonymisation you will continue to be processing personal data. The data subject is the living individual that is identified in, or identifiable from, the personal data. While such information is personal data under the DPA 2018, it is exempted from most of the principles and obligations in the GDPR and is aimed at ensuring that it is appropriately protected for requests under the Freedom of Information Act 2000. This means personal data has to be information that relates to an individual. Sensitive personal data is also covered in GDPR as special categories of personal data. In data protection and privacy law, including the General Data Protection Regulation (GDPR), it is defined beyond the popular usage in which the term personal data can de facto apply to several types of data which make it able to single out or identify a natural person. The UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals. you need to take adequate lengths to protect it. We intend to publish further guidance on the provisions of the DPA 2018 in due course. “…Personal data which have undergone pseudonymisation, which could be attributed to a natural person by the use of additional information should be considered to be information on an identifiable natural person…”. In others, it may be less clear and you will need to carefully consider the information you hold to determine whether it is personal data and whether the GDPR applies. This will extend PECR’s reach to include ‘over the top’ communications such as voice over internet protocol providers, or VoIPs, (like Skype) and social media messaging services (for example, WhatsApp). This rule means you may be able to email your own customers, even after GDPR comes into force. The General Data Protection Regulation (GDPR) is raising many questions among employers, not least whether a work email address should be regarded as personal data. In the meantime, this existing guidance on anonymisation is a good starting point. 4 (1). This resource should be read together with the Australian Privacy Principle (APP) guidelines. GDPR doesn't goes into the specifics. 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