I think context comes into it.
An e-mail address is clearly personal data if it is part of (or can be
linked to) a customer record, even if the address itself is entirely
pseudonymous (whiterabbit@somefreeisp ... for example). If the address is
then broadcast, that is a disclosure of personal data to unauthorised
people. I believe that would be a breach of Principle 7 and probably
Principle 1, even if the context in which it was disclosed did not give the
recipients enough information to identify the person with any certainty.
Part of my reason for thinking this is that the consequences for the
individual could be the type of consequences which would normally be the
concern of the DPA - such as receiving intrusive and unwanted e-mails. The
extreme case would be where an unusual personal name is linked to a company
name in the e-mail address, allowing a person to be stalked because someone
had discovered their place of work (or even worse allowing the 'wrong'
person to be stalked).
If, however, it is possible to sign up to an e-mail newsletter, for example,
by providing an e-mail address and no other personal information, then the
owner of the list may not be holding personal data, because they do not have
enough other information to identify the individuals, even if the e-mail
address itself is suggestive (by which I mean [log in to unmask], for
example).
So it's not usually the e-mail address itself which is personal data, but
the assemblage of data - which may well include an e-mail address.
Paul Ticher
0116 273 8191
22 Stoughton Drive North, Leicester LE5 5UB
----- Original Message -----
From: "Graham Wilford" <[log in to unmask]>
To: <[log in to unmask]>
Sent: Thursday, December 02, 2010 8:08 PM
Subject: Is an email address personal data?
Hi
Recently an organisation sent me some information as part of a wider
emailing and did not use bcc, meaning my address was opened to all.
I did not provide permission to use the address but have recieved mailings
before and they were fine. But now all the mailing list know my email.
I am aware of Lindquist and Durant and as a result am not sure if an email
address alone now consitutes personal data.
The email construct was similar to [log in to unmask]
Views?
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