The discussion has missed the main point of my blog which is not limited to
IP addresses but the following (thanks to Recital 26 of Directive 95/46/EC).
Suppose an organisation collects non-identified data (e.g. an IP address;
location data) knowing that these data are to be disclosed to another
organisation who will then identify (or attempt to identify) an individual
(e.g. who is attached to a particular IP address, or at a location) then the
first organisation is a data controller, thanks to Recital 26 (and obviously
the second organisation is also a controller). For the first organisation to
be a controller in the context of a disclosure, the IP address, location
data in themselves have to be personal data (and the right to object to
marketing etc is engaged). This is what Ryneš is suggesting.
See blog on: http://amberhawk.typepad.com/
C
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