Generic email account addresses can be a challenge. If the reply is signed by an individual, arguably the address would be the PD of that individual *for that email*.
Even if an email is not individually signed, if the use of the account to send that email can be under query linked to an individual (e.g. though system logs, Active Directory, etc.), the address would be the PD of that individual *for that email*.
The drafters of the Directive and the DPA had no idea of how computer systems and usage would develop; no more did the more recent drafters of the GDPR, no matter what "future-proofing" they have attempted. I foresee as many challenges for organisations - particularly in the private sector - in complying with it as they face now. A major difference being that non-compliance could prove far more expensive than today.
M
> On 11 Apr 2016, at 04:58, Roland Perry <[log in to unmask]> wrote:
>
> In article
> <[log in to unmask]>,
> [log in to unmask] writes
>
>> Actually, even if your email address is just a number, as is the case in
>> some organisations, it still - with other information held by the data
>> controller - identifies a living individual.
>
> Not necessarily. We have an email address "press@" which goes to whoever
> is taking calls from the press a the moment.
>
> However I strongly agree that there must be a *presumption* that email
> addresses are *very often* personal data, and should therefore
> beprocessed appropriately.
>
> [1] My own interest in this, for a very long time now, is the issue of
> spammers processing email addresses, thus arguably infringing the
> general DPA law, let alone any specific anti-spam laws.
> --
> Roland Perry
>
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