I have a different view on phone numbers from that on email addresses. A
mobile phone number is simply a collection of numbers. Unlike (eg) a
National Identity number is it not, of itself, capable of identifying
anything except a phone handset or SIM card. It is thus not personal data.
However one is capable of arguing that a mobile phone number, since it is a
personal attribute, is capable *with other information* of identifying a
living individual in the same manner as a photograph.
Thus the context of storage and retrieval of the mobile phone number, in my
view, creates scenarios where it may be able to be construed as personal
data.
It differs from an email address since an email address leads "always" to a
person and not to a computer.
Tim Trent - Consultant
Direct: +44(0)1344 392644 Mobile:+44(0)7710 126618
email: [log in to unmask]
<blocked::mailto:[log in to unmask]>
Marketing Improvement Limited, Abbey House, Grenville Place, Bracknell,
United Kingdom, RG12 1BP <blocked::http://www.marketingimprovement.com/>
http://www.marketingimprovement.com
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From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Julian Curmi
Sent: Monday, June 21, 2004 9:47 AM
To: [log in to unmask]
Subject: [data-protection] DP - Email Address - Personal Data? So What About
a Mobile Phone Number?
The discussion about whether or not an email address constitutes personal
data or not, is very interesting. So what about a mobile phone number,
whether or not one's own personal mobile phone number or a mobile phone
number given to an employee by the respective employer?? May one argue on
the same lines??
Regards
Julian Curmi
Information Security Officer
Bank of Valletta plc
Malta, Europe
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