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I concur. There’s no way you could identify an individual chess player from a generic email address unless you had specific knowledge of one or more individuals
who were members of that club.
Ciaran Ward
Senior Information Co-ordinator
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From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]] On Behalf Of Donald Henderson - CHX
Sent: 11 August 2015 16:22
To: [log in to unmask]
Subject: Re: [data-protection] Group email as personal data? Friday comes early
In the examples you give, group membership, i.e. the email address, on its own is not going to be enough to identify an individual. However, as soon as any
other information is added, like the content of an email, there would have to be careful scrutiny to decide whether there was personal data involved.
Donald Henderson
Information Compliance Manager
Perth & Kinross Council
From: This list is for those interested in Data Protection issues
[mailto:[log in to unmask]]
On Behalf Of Lawrence Serewicz
Sent: 11 August 2015 15:48
To: [log in to unmask]
Subject: [data-protection] Group email as personal data? Friday comes early
Dear All,
I think this is a simple question. However, I need to check with the list to gain views.
A group of people, say chess players, have a group email address for their club. The send emails for the group from the email address
[log in to unmask] [Completely fictitious email address]
Is the email address personal data? The legislation says:
“personal data” means data which relate to a living individual who can be identified—
(a)from those data, or
(b)from those data and other information which is in the possession of, or is likely to come into the possession of, the data controller,
Can a living individual be identified from the email address? I may know the members of the club (say there are 8) does that make the group email address their personal data?
What if the membership is less well known? Perhaps a family has an email address ([log in to unmask]) and there are 8 members
of the family. Are any of the family members who can be identified from the data or what is likely to be known by the data controller?
If the data controller, say the local store, sends out an email to various groups and includes
[log in to unmask] have they disclosed personal data? If so, whose personal data have they disclosed? All the members of the family?
In sum, when does a group membership identify an individual?
Best,
Lawrence
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