What is ‘personal data’ under EU data protection law?

Golden Data Law
Golden Data
Published in
34 min readNov 18, 2018

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Leslie Dughi dressed as a witch for Halloween in Tallahassee, Florida (1972) — Florida Memory

The definition of “personal data” under EU data protection law

Key point:

The four “building blocks” of the definition of personal data are:

(1) “any information”

(2) “relating to”

(3) “an identified or indentifiable”

(4) “natural person”

The definition of personal data under GDPR is identical to the definition under the 1995 Data Protection Directive.

Article 4 (1)

‘Personal Data’ means any information relating to an identified or identifiable natural person (‘data subject’) […]

The definition contains four closely intertwined building blocks that feed of each other but should be separately analyzed for the sake of clarity. Those blocks are “any information” “relating to” “an identified or indentifiable” “natural person”.

First “building block”: “ANY INFORMATION”

Key points:

(1) The concept of personal data includes both objective and subjective statements.

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Golden Data Law
Golden Data

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